PR-1712 - Level 3 Audit (Engineering Operations)

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Petroleum Development Oman L.L.C.
Document Title: AI-PS Assurance
Document ID
Document Type
Security
Discipline
Owner
Issue Date
Version
PR-1712
Procedure
Unrestricted
Technical Safety Engineering
MSE4 – Head of Technical Safety Engineering
12 May 2012
2.0
This document is the property of Petroleum Development Oman, LLC. Neither the whole nor any part of
this document may be disclosed to others or reproduced, stored in a retrieval system, or transmitted in
any form by any means (electronic, mechanical, reprographic recording or otherwise) without prior
written consent of the owner.
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i
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Document Authorisation
Authorised For Issue – May 2012
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ii Revision History
The following is a brief summary of the 4 most recent revisions to this document. Details of all
revisions prior to these are held on file by the issuing department.
Revision
No.
Date
Author
Scope / Remarks
2.0
Feb-12
Ian Jewitt MSE4
Revised to cover the new content and
merging of relevant material from
Revision 1.0
1.0
Sep-07
Robin Norman UOP6
New Procedure
iii Related Business Processes
Code
Business Process (EPBM 4.0)
EP71
Produce Hydrocarbons
EP72
Maintain and Assure Facilities
iv Related Corporate Management Frame Work (CMF)
Documents
The related CMF Documents can be retrieved from the CMF Business Control Portal.
Refer to Appendix 7
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TABLE OF CONTENTS
1
2
3
Introduction ............................................................................................................................ 6
1.1
Background ...................................................................................................................... 6
1.2
Purpose ............................................................................................................................ 6
1.3
Scope ............................................................................................................................... 6
1.4
Distribution/Target Audience ............................................................................................ 7
1.5
Performance Monitoring ................................................................................................... 7
1.6
Review and Improvement................................................................................................. 7
1.7
Step-out and Approval ...................................................................................................... 7
AI-PS Assurance Framework ................................................................................................. 8
2.1
CCPS Pillars of Process Safety ....................................................................................... 9
2.2
PDO Element Guides ..................................................................................................... 10
Roles and Responsibilities ................................................................................................... 11
3.1
Level 2 AI-PS Assurance ............................................................................................... 11
3.1.1
Initiate the Level 2 Assurance .................................................................................. 12
3.1.2
Complete the Level 2 Self-Assessment ................................................................... 13
3.1.3
Prepare for the level 2 AI-PS Audit .......................................................................... 13
3.1.4
Execute the Level 2 Audit ........................................................................................ 14
3.1.5
Manage Level 2 Audit Action Items ......................................................................... 17
3.1.6
Manage the Assurance Process .............................................................................. 17
3.2
Level 3 AI-PS Assurance ............................................................................................... 17
3.2.1
Initiate the Level 3 Assurance .................................................................................. 18
3.2.2
Execute the Level 3 Assurance ............................................................................... 18
3.2.3
Manage Level 3 Assurance Action Items ................................................................ 19
3.2.4
Manage the Assurance Process .............................................................................. 19
Appendix 1 - Level 2 AI-PS Audit Terms Of Reference (Template) ............................................ 20
Appendix 2 - Audit Working Paper (Example)............................................................................. 26
Appendix 3 - Level 3 Assurance Plan (Example) ........................................................................ 28
Appendix 4 - Typical Level 3 Production Operation Function Audit. ........................................... 29
Appendix 5 - Process Safety Management Framework .............................................................. 30
Appendix 6 - Abbreviations.......................................................................................................... 45
Appendix 7 – Reference Material ................................................................................................ 46
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1
Introduction
1.1
Background
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An explosion at Longford gas plant occurred on 25 September 1998 resulting in two
fatalities and a 19 day interruption in gas supply to the state of Victoria, Australia. An
audit conducted by a corporate team six months prior to the explosion had determined
that the gas plant was successfully implementing its process safety management
system. However, a Royal Commission subsequently investigated the explosion and
found significant deficiencies in the areas of (1) risk identification, analysis and
management; (2) training; (3) operating procedures; (4) documentation; and (5)
communications. These long-standing problems had not been detected by the prior
audit.
Critical evaluation of the AI-PS management system is one element of learning from
experience. This procedure covers formal methods for performing periodic Asset
Integrity – Process Safety (AI-PS) framework audits, which should reduce risk by
proactively identifying and correcting weaknesses in management system design and
implementation.
Since 2010, PDO has implemented a dedicated program of level 2 (cross-directorate)
and level 3 (asset verification) assurance for AI-PS. The initial program was based on
the Center for Chemical Process Safety (CCPS) Guidelines for Risk Based Process
Safety. An external audit at the end of 2010 recommended that PDO established a riskbased AI-PS assurance procedure that was tailored to PDO business. The procedure
was trialled in the 2011 AI-PS assurance program and was formalised in the first issue
of this procedure in 2012.
IMPORTANT NOTE: This procedure has taken the procedure reference number of
‘Level 3 Audit’ (PR-1712) previously owned and administered by the UOP Function. As
many of the aspects covered in this procedure are applicable to those in the original PR1712 it was agreed that the two procedures be merged.
1.2
Purpose
The procedure defines the process for evaluating the implementation of AI-PS
requirements in PDO, to ensure that they are in place and functioning in a manner that
protects employees, stakeholders, the environment and physical assets against process
safety risks.
1.3
Scope
The procedure covers level 2 and level 3 AI-PS assurance, where:

Level 2 assurance is a 2nd party (independent of the asset) auditing of a single
asset. This is also referred to as a cross-directorate audit.

Level 3 assurance is an asset checking or verifying its own processes.
The procedure does not cover level 1 AI-PS assurance (i.e. 3rd party auditing of the
PDO AI-PS management system), which is addressed by the Level 1 Corporate HSE
Audit program and the Corporate HSE Audits procedure PR-1969. However, in general
Level 1 AI-PS audits are expected to take place once every three years.
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1.4
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Distribution/Target Audience
AI-PS Element Owners, Operations Managers, Delivery Team Leaders and AIPSALT
team members / Process Safety Element Champions.
1.5
Performance Monitoring
‘Completion of Level 2 self assessments and cross-directorate audits’ is included as an
AI-PS Key Performance Indicator (KPI). The KPI is calculated as a milestone measure
against the level 2 assurance plan.
‘Audit Action Closure’ is included as an AI-PS Performance Indicator (PI). The PI is
calculated as the percentage of overdue AI-PS audit actions of all open Level 2 AI-PS
audit actions. See Section 3 for further information about action close out.
1.6
Review and Improvement
As a minimum, the procedure shall be reviewed and updated on a three yearly basis by
the Document Owner.
1.7
Step-out and Approval
This procedure is mandatory and shall be complied with at all times. Should
compliance with the procedure be considered inappropriate or the intended activity
cannot be effectively completed or safely performed, then step out authorisation and
approval must be obtained from the Document Owner, prior to any changes or
activities associated with the procedure being carried out
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2
AI-PS Assurance Framework
The Center for Chemical Process Safety (CCPS) developed a Risk Based Process
Safety framework that was organised into four pillars, which were further made up of
twenty elements as shown in the figure 2.1 below.
Asset Integrity - Process Safety Management
Commit to
Process Safety
Understand
Hazards & Risks
Manage Risk
Learn from
experience
Process safety
culture
Process
knowledge
management
Plant operating
procedures
Incident
investigation
Permit To Work
Measurement and
metrics
Compliance with
standards
Process safety
competency
Workforce
involvement
Stakeholder
outreach
Hazards and
Effects
Management
Process
Technical integrity
Contractor
management
Training and
performance
assurance
Assurance
Management
review and
continuous
improvement
Management of
change
Operational
readiness
Conduct of
operations
Emergency
management
Figure 2.1: AI-PS Assurance Framework
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CCPS Pillars of Process Safety
Appendix 4 provides a summary of the expectations set by the CCPS Guidelines for
each element of Risk Based Process Safety. The expectations may be useful for a
Level 1 Audit of PDO AI-PS Management. At a high level, these expectations are:
To commit to process safety, facilities should focus on:

Developing and sustaining a culture that embraces process safety;

Identifying, understanding and complying with codes, standards, regulations,
and laws;

Establishing and continually enhancing organizational competence; and

Soliciting input from and consulting with all stakeholders, including employees,
contractors, and neighbours.
To understand hazards and risk, facilities should focus on:

Collecting, documenting, and maintaining process safety knowledge; and

Conducting hazard identification and risk analysis studies.
To manage risk, facilities should focus on:

Developing written procedures that (1) describe how to safely start up, operate,
and shut down processes, (2) address other applicable operating modes, and
(3) provide written instructions that operators can execute when they encounter
process upsets / unsafe conditions.

Implementing an integrated suite of safe work policies, procedures, permits, and
practices to control maintenance and other non-routine work.

Executing work activities to ensure that equipment is fabricated and installed in
accordance with specifications, and that it remains for service over its entire life
cycle.

Managing contractors, and evaluating work performed by contractors, to ensure
that the associated risks are acceptable; ensuring that contractors are not
exposed to unrecognized hazards or undertake activities that present unknown
or intolerable risk.

Providing training and conducting related activities to ensure reliable human
performance at all levels of the organization.

Recognizing and managing changes.

Ensuring that units, and the people who operate them, are properly prepared for
start-ups.

Maintaining a very high level of human performance, particularly among
operators, maintenance personnel, and others whose actions directly affect
process safety.

Preparing for and managing emergencies.
To learn from experience, facilities should focus on:
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
Investigating incidents that occur at the facility to identify and address the root
causes.

Applying lessons from incidents that occur at other facilities within the company
and within the industry.

Measuring performance and striving to continuously improve in areas that have
been determined to be risk significant.
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
Auditing process safety management systems as well as the performance of
work activities that make up the management system.

Holding periodic management reviews to determine if the management systems
are working as intended and if the work activities are helping the facility
effectively manage risk.
PDO Element Guides
The Company has developed AI-PS Element Guides that translate the CCPS Risk
Based Process Safety guidelines into requirements in the PDO Corporate Management
Framework. The PDO AI-PS Element guidelines are contained in GU-668 AI PS
Elements Guide. For each element, the guidelines identify:

The functional / corporate element owner. This is the individual who is
accountable for maintaining the individual Element Guide and Corporate
Management Framework standards associated with the Element.

Background, aims, objectives and scope of the element.

Level 2 self assessment protocols. These are the protocols that shall be used
for the asset level 2 self assessments.

Level 3 verification checklists. These are checklists developed by the function
that should be used by the assets in the execution of their level 3 assurance
schedule.
Refer to Appendix 4 for examples of the requirements of a Typical Level 3
Production Operation Function Audit.
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3
Roles and Responsibilities
3.1
Level 2 AI-PS Assurance
Audit Team Members
Audit Peer Reviewer
R
I
C
C
R
A
R
C
R
S
A
R
S
A
R
S
I
I
C
S
C
A
R
S
I
I
I
I
R
I
I
I
C
R
A
R
C
I
I
I
C
I
I
A
S
S
Audit Team Leader
C
AIPSALT PS Element
Champions
I = Informed
Audit Coordinator(s):
DTL or equivalent
C = Consulted
Auditee(s): Operations
Managers
S = Supports
Sponsor(s): asset
Director(s)
A = Accountable
AI-PS Element Owners
AI-PS Champion
R = Responsible
AI-PS Assurance
Element Owner
The RASCI chart for level 2 Asset Integrity – Process Safety (AI-PS) assurance is
shown in Table 3.1. Guidance for the execution of individual tasks shown in the RASCI
chart is provided in Sections 3.1.1 to 3.1.6.
Task
1.0
Initiate the level 2 assurance
1.1
Establish and maintain a risk-based
level 2 AI-PS assurance plan.
A
S
1.2
Identify risk priorities, i.e. AI-PS
Elements to be addressed.
C
A
1.3
Assign
leader.
A
R
I
1.4
Provide the resources to ensure
that a competent audit team is
available.
A
S
S
competent
audit
team
2.0
Complete the level 2 AI-PS selfassessment
2.1
Complete level 2 self-assessment
against the level 2 AI-PS protocols.
3.0
Prepare for the level 2 AI-PS
audit
3.1
Prepare and approve the TOR for
level 2 audit.
3.2
Finalise the schedule of level 2
audit.
3.3
Issue pre-read materials for level 2
audit.
I
3.4
Conduct level 2 audit team briefing
on TOR, audit methodology and
reporting requirements.
A
A
S
4.0
Execute the level 2 audit
4.1
Conduct level 2 audit.
4.2
Level 2 audit close-out meeting.
A
S
4.3
Issue level 2 audit report.
I
I
4.4
Issue summary report of level 2
audits.
I
A
5.0
Manage level 2 audit action items
5.1
Ensure remedial actions from the
audit are properly addressed and
that actions taken are documented.
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C
S
R
S
I
I
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S
5.3
Approve changes to remedial
actions, due dates/action parties.
A
S
S
6.0
Manage the assurance process
6.1
Maintain PDO processes and
procedures for AI-PS assurance.
6.2
Seek
feedback
assurance program.
6.3
Verify the rigour of the PSR process
and arrange periodic external
participation.
AI-PS Champion
I = Informed
on
annual
A
R
C
A
C
C
A
Audit Peer Reviewer
S
C = Consulted
Audit Team Members
AIPSALT PS Element
Champions
A
S = Supports
Audit Team Leader
Audit Coordinator(s):
DTL or equivalent
Approve the closure of actions
relevant to AI-PS Element.
A = Accountable
Sponsor(s): asset
Director(s)
5.2
R = Responsible
AI-PS Assurance
Element Owner
Auditee(s): Operations
Managers
AI-PS Element Owners
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C
C
C
C
C
C
C
C
C
Table 3.1: RASCI Chart for Level 2 AI-PS Assurance
Mapping roles in the RASCI against positions in the organisation:
3.1.1

AI-PS Champion: The Director accountable for AI-PS in the Corporate HSE
Plan.

AI-PS Assurance Element Owner: The Owner of this procedure.

AI-PS Element Owners: Corporate or functional owners of individual Elements
as identified in GU-668.
Initiate the Level 2 Assurance
Establish and maintain a risk-based level 2 AI-PS assurance plan.

Issue a three-year level 2 AI-PS assurance plan providing coverage of all
assets. Gain Operations Leadership Team (OLT) endorsement.
Identify risk priorities, i.e. AI-PS Elements to be addressed:

Conduct AI-PS risk review workshop involving AI-PS working group to identify
AI-PS Elements to be in scope of level 2 assurance.
Assign competent audit team leader.
Provide the resources to ensure that a competent audit team is available:
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
Agree date for level 2 audits with OLT.

Issue list of proposed audit team members to OLT and request release of staff.
Gain agreement.

Block audit dates in audit team member’s calendar.
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3.1.2
Complete the Level 2 Self-Assessment
Complete level 2 self-assessment against the level 2 AI-PS protocols:
 Download latest version of level 2 self-assessment tracker and AI-PS Element
Guides (GU-668) and distribute to Process Safety Element Champions.
 Identify asset focal point for level 2 self-assessment tracker.
 Kick off level 2 self-assessment in AIPSALT meeting.
 Monitor completion of the level 2 self-assessment.
3.1.3
Prepare for the level 2 AI-PS Audit
Prepare and approve the Terms Of Reference (TOR) for level 2 audit:

Develop draft TOR for the level 2 audit and circulate for comment.
Appendix 1 for draft level 2 audit TOR.

Issue final version of the TOR for the level 2 audit.
See
Finalise the schedule of level 2 audit:

Review flight schedules for the audit period.

Propose draft schedule and outline interviewees.
Audit Team Leader and Audit Coordinator.

Audit Coordinator to confirm that logistics including flights, accommodation, land
transport and interviews have been arranged.

Identify training requirements for external audit team members, e.g. H2S
Awareness and Escape training for access to sour facilities. Arrange training (if
required).

Arrange logistics for external audit team members (if required), e.g. airport and
hotel pick-up / drop-off; transport to / from training institutes; gate passes; etc.
Gain agreement between
Issue pre-read materials for level 2 audit.

To facilitate the efficient and effective execution of the audit, it is required that
the self-assessment against the level 2 AI-PS protocols, Plant Operating
Manual and Operations HSE Case shall be forwarded or made accessible to
Audit Team Leader at least one (1) week prior to the audit (can be in electronic
form, via website / LiveLink access or hard copy). This will allow a review of the
auditee’s arrangements and enable set-up of the audit to ensure focus on the
areas likely to represent the highest risk to the business.
Conduct level 2 audit team briefing on TOR, audit methodology and reporting
requirements:
Page 13

Produce / update audit team briefing materials.

Engage AI-PS Element Owners to participate as part-time presenters.

Organise room and send meeting invitation for audit team briefing.

Deliver audit team briefing on TOR, audit methodology, level 2 protocols and
audit reporting.
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Execute the Level 2 Audit
Conduct level 2 audit:

The audit will be conducted using the PDO HSE Audit methodology summarized
below. Findings shall be classified and the implementation of AI-PS Elements
assessed in accordance with the criteria shown below.

The methodology will use a “risk-based” approach and a general auditing
approach in line with good industry practice. Team members will gather
information by field observation, through interviews and including checks of
hardware and documentation. Audit evidence will be based upon sampling of
the available information and therefore should not be considered all-inclusive or
exhaustive. Conscientious efforts will be made to verify findings and to confirm
the validity of recommended actions. Where judgment is required, the result will
be determined by consensus within the audit team.

Audit observations, potential findings and recommendations should be recorded
in Audit Working Papers (AWPs); see Appendix 2 for an example. One AWP
should be developed for each AI-PS Element within the scope of the audit.

Classification of the audit findings shall be in accordance with the Rating Level
Table 3.1. All findings are to be classified based upon the professional
judgment of the audit team. The primary criterion for rating each finding is the
adequacy of the control for the risk against the expectation set in the relevant
PDO AI-PS Element Guides (GU-668).
Weakness Level
Definition
Serious (S)
The finding is likely to cause a high undesirable effect on the
achievement of PDO’s objectives, therefore warranting
immediate reporting to senior management e.g. Technical
Director level.
High (H)
The finding is likely to cause a high undesirable effect on the
achievement of one of PDO’s objectives, warranting reporting to
the auditee’s management.
Medium (M)
The finding is likely to cause a measurable undesirable effect on
the achievement of one of PDO’s objectives.
Low (L)
The weakness is unlikely to have a measurable impact on PDO’s
objectives, but its correction would enhance the risk based
control framework.
Table 3.1: Rating Level Table

No audit opinion will be provided. Assessments of the implementation of the AIPS Elements in line with the PDO AI-PS Element Guides (GU-668) will be
indicated by reference to three possible categories:
Controls Acceptable
None, or a few Low and/or Medium rated findings are reported which indicate that
a “once-off” rather than process or system structural weaknesses is present or
that general enhancement of the controls, process, or system framework is not
needed (Few = 2 or less).
Controls Need Improvement
Some Medium and / or one or more High rated findings are reported which
indicate a weakness in key controls / barriers or in a part of the process or system
structural framework (Some = 3 or more).
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Controls Need Major Improvement
Three or more High and/or one or more Serious rated findings are reported
indicating failures in key controls / barriers or across a significant part of the
process or system structural framework.
Table 3.2: Control Acceptability Table

A further qualitative description will be provided as part of the Summary and
Conclusions, to summarise the overall outcome and highlighting the AI-PS
Elements where findings are identified. This will include a table that depicts a
reference to each finding and the control acceptability assessment for each AIPS Element; see Table 3.3 for example.
Plant operating
procedures /
manuals

Conduct of
operations
PTW

Emergency
management
Process safety
competency
Technical Integrity

Workforce
involvement
Contractor
management

Stakeholder outreach
Training and
performance
assurance
Process safety
culture

Compliance with
engg. standards
Process knowledge
management

HEMP

f1-H
Management of
change
f2-M
f3-M
f4-M
f5-H
f6-H
f7-H

Incident investigation
Measurement and
metrics
Assurance

f8-S
Management review
and continuous
improvement
Operational
readiness
Table 3.3: Overall Outcome Table

Page 15
During the audit the audit team may come across weaknesses in an AI-PS
Element, which have already been identified by the auditee in the selfassessment. In some of these cases the auditee may be able to claim ‘work-inprogress’ (WIP) when the following criteria have been met:
o
Relevant issues and actions are identified and documented prior to the
start of the audit.
o
For these issues and actions an implementation plan was already in
place prior to the start of the audit with milestones set and resources
allocated together with evidence of implementation having begun.
o
During the audit, the follow-up process was found to be satisfactory,
taking into account the track record of the business in closing out action
items.
o
A risk assessment had been conducted and interim mitigations to
control the risk area were in place, and deemed effective by the audit
team.
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Where testing by the audit team proves that the above criteria can be
met, no specific findings shall be raised for these issues in the audit
report. However, due reference will be made in the executive summary
of the audit report as to the degree of reliance that was placed on the.
Such issues will also not have major impacts on the opinion. Where
one of the above criteria has not been met, reliance cannot be placed
on the process. Another finding will therefore be raised to ensure that
relevant actions are taken. The audit opinion will take such audit
findings into account.

The draft audit report shall undergo a peer review prior to the discussion with
the auditee.

It is good practice to hold a no surprises meeting involving the auditee, audit
coordinator and audit team leader to discuss the significant findings of the audit,
prior to the formal close-out meeting.
Level 2 audit close-out meeting:

The audit team will present the audit results to the auditee and their
management at the conclusion of the audit.
This closing meeting or
presentation shall be conducted at the end of the audit or as pre-arranged
between the auditee and the Audit Team Leader. The purpose of this meeting
is to formally communicate the findings and the assessment of the acceptability
of controls to the auditee and the management team and to ensure clarity of
understanding. The findings, associated classifications, and acceptability of
controls shall be considered “frozen” and only editorial changes allowed may be
considered.
Issue level 2 audit report:

Within seven (7) days of the audit conclusion, the Audit Team Leader shall send
a “Draft for Review” copy of the audit report to the Auditee. The Auditee will
work with his/her organisation to define the most appropriate way to address the
findings and recommendations, assign the action party and determine the
planned completion date. The Auditee shall have 14 days to comment and to
complete the “Action”, “Action Party” and “Due Date” fields for each of the
findings / recommendations. The Audit Team Leader will review the actions and
timings proposed by the site and will request clarification if required to ensure
that actions do address the audit findings. When substantial agreement has
been reached on the contents of the report, the report will become Final.

Where agreement on findings or appropriate actions to address findings and/or
recommendations cannot be reached, the Audit Team Leader may discuss with
the next level of management of the auditee’s business and agree a forward
plan to resolve the issue. In cases where resolution between the auditor and
auditee / auditee’s line management cannot be reached, they shall be escalated
to the AI-PS Champion. If the disputed area cannot be resolved, the Audit
Team Leader view will prevail although the auditee will have the right to insert a
management comment to provide his/her point of view (on the appropriateness
of actions only).

Once the report is completed, it shall be distributed as agreed with the auditee.
Issue summary report of level 2 audits (if required):

Page 16
When multiple level 2 audits have been conducted in the Company during the
year, there is an opportunity to identify and report on common issues between
the assets. These common issues are generally for the attention of the AI-PS
Element Owners as the functional /corporate owners of
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3.1.5
Manage Level 2 Audit Action Items
Ensure remedial actions from the level 2 audit are properly addressed and that actions
taken are documented:

Level 2 audit actions shall be communicated and agreed with those employees
and contractors assigned the responsibility for closing the actions and the
relevant Technical Authority responsible for approving the closure.

All items are to be assessed, tracked and closed via the corporate audit tracking
system, e.g. FIM. Other tracking arrangements may be used for lower priority
items.

The level 2 audit report and documented resolution of actions shall be kept for
the life of the asset.
Approve the closure of actions relevant to AI-PS Element.

Level 2 audit recommendations are resolved (closed) when they are
implemented, or justifiably rejected.

The asset Director should monitor the
actions/improvements against Serious findings.

The Operations Manager (or equivalent) should monitor the implementation of
agreed actions/improvements against High findings.

The Delivery Team Leader (or equivalent) should monitor the implementation of
agreed actions/improvements against Medium findings.

Closure statements shall provide adequate information and evidence to verify
that action has been completed.
implementation
of
agreed
Approve changes to remedial actions, due dates/action parties.
3.1.6
3.2

Approval of any changes to be given in consultation with the appropriate level of
authority, i.e. asset Director for Serious findings; Operations Manager for High
findings; and Delivery Team Leader for Medium findings.

If an assigned action party changes roles prior to completion of the action, the
action shall be reassigned to a new action party by the Auditee.

Changes to action item due dates require the approval of the Auditee.
Manage the Assurance Process

Maintain PDO processes and procedures for AI-PS assurance.

Seek feedback on the annual assurance program.

Verify the rigour of the PSR process and arrange periodic external participation.
Level 3 AI-PS Assurance
The RASCI chart for level 3 AI-PS assurance is shown in Table 3.2. Guidance for the
execution of individual tasks shown in the RASCI chart is provided in Sections 3.2.1 to
3.2.4.
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I = Informed
AIPSALT PS Element
Champions
C = Consulted
DTL or equivalent
S = Supports
Operations Managers
A = Accountable
AI-PS Element Owners
AI-PS Assurance
Element Owner
R = Responsible
A
R
C
A
S
I
A
S
A
I
R
Level 3 Auditor
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Task
1.0
Initiate the level 3 assurance
1.1
Establish and maintain a risk-based level 3 AIPS assurance plan.
2.0
Execute the level 3 assurance
2.1
Conduct level 3 audit.
3.0
Manage level 3 assurance action items
3.1
Ensure remedial actions from the level 3 audit
are properly addressed and that actions taken
are documented.
3.2
Approve the closure of actions relevant to AIPS Element.
4.0
Manage the assurance process
4.1
Maintain PDO processes and procedures for
AI-PS assurance.
A
R
R
C
Mapping roles in the RASCI against positions in the organisation:
3.2.1

AI-PS Assurance Element Owner: The Owner of this procedure.

AI-PS Element Owners: Corporate or functional owners of individual Elements
as identified in GU-668.
Initiate the Level 3 Assurance
Establish and maintain a risk-based level 3 AI-PS assurance plan.
3.2.2

Issue an annual level 3 AI-PS assurance plan.
endorsement.

The schedule of the level 3 assurance shall be risk-based and should be
included in the asset HSE business plan. An example level 3 AI-PS assurance
plan is shown in Appendix 3.

Level 3 AI-PS assurance is managed and resourced by the AIPSALT. The
assurance of each element is coordinated by an asset Process Safety Element
Champion (PSEC). Compliance with the level 3 AI-PS assurance plan should
be monitored by the AIPSALT.
Execute the Level 3 Assurance

Page 18
Gain Operations Manager
Conduct level 3 audit.
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3.2.3
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Manage Level 3 Assurance Action Items
Ensure remedial actions from the level 3 audit are properly addressed and that actions
taken are documented.

The results of level 3 assurance shall be summarised and reported to the
AIPSALT.

The AIPSALT shall track actions resulting from level 3 assurance.
Approve the closure of actions relevant to AI-PS Element.
3.2.4

Level 3 audit actions are resolved (closed) when they are implemented, or
justifiably rejected.

Close-out of actions to be approved by the Process Safety Element Champion.
Manage the Assurance Process

Page 19
Maintain PDO processes and procedures for AI-PS assurance.
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Appendix 1 - Level 2 AI-PS Audit Terms of Reference (Template)
Terms of Reference
Cross-Directorate Process Safety Audit of XXX Asset
(PDO Level 2 AI-PS Audit)
Audit Ref #
XXX
Sponsor
NAME
JOB TITLE
REF IND
Auditee
NAME
JOB TITLE
REF IND
Facility Audit
Coordinator
NAME
JOB TITLE
REF IND
AI-PS Champion
NAME
JOB TITLE
REF IND
AI-PS Assurance
Element Owner
NAME
JOB TITLE
REF IND
Audit Team Leader
NAME
JOB TITLE
REF IND
Audit Team
NAME
JOB TITLE
REF IND
NAME
JOB TITLE
REF IND
NAME
JOB TITLE
REF IND
NAME
JOB TITLE
REF IND
Peer Reviewer
NAME
JOB TITLE
REF IND
Locations to be
covered
XXX
Period of audit
DD MMM YYYY to DD MMM YYYY
Date issued
Rev XXX: DD MMM YYYY
Objectives
The objectives of the audit are:
 To assess the adequacy & effectiveness of the implementation of AI-PS
requirements.
 Where weaknesses are identified, to provide recommendations and guidance
on what is expected and needed to demonstrate adherence to PDO’s AI-PS
requirements and using examples of PDO and external implementation as
examples of good practice.
Scope
The scope includes all process facilities & activities under the operational control of
XXX asset as described in its Operations HSE Case & includes interfaces with other
business activities, contractors & projects.
Not every aspect at each facility will be audited, as the cross-directorate audit is “riskbased”. Locations, which are to be sampled, include XXX offices in Muscat, XXX
offices in the interior and XXX facility.
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Specific focus areas have been defined for the AI-PS L2 cross-directorate audit in
YEAR, although these may not be exhaustive:
Element XXX
DEFINITION OF ELEMENT SCOPE
Element XXX
DEFINITION OF ELEMENT SCOPE
Element XXX
DEFINITION OF ELEMENT SCOPE
Standards
The audit will be carried out against the following standards:
1. PDO’s HSE Commitment and Policy;
2. Oman’s laws and regulations;
3. PDO’s Corporate Management Framework;
4. PDO’s AI-PS Assurance Procedure (PR-1712) and AI-PS Element Guides GU668).
Costs
The mobilisation and manpower costs for external team members will be allocated to
the central AI-PS Must Win account.
Schedule
The audit takes place during the period from DD MMM YYYY to DD MMM YYYY.
A proposed schedule containing detail on the proposed site fieldwork and interviewees
will be sent and agreed separately. The auditee will submit the organisational chart
and general site processes descriptions to the Audit Team Leader to allow for the
schedule to be made specific to the auditee’s organisation as detailed in their latest
Operations HSE Case.
The asset shall finalise and agree the draft schedule two (2) weeks prior to the audit.
During the execution of the audit the Audit Team Leader may request to modify the
schedule to accommodate additional interviews or sample locations.
Interviews shall generally be conducted in the workplace of the interviewee (e.g. offices
of management, workshops of maintenance persons, control rooms of operations
persons, etc.). Arrangements shall be requested for detailed inspections of facilities
consisting of “walk-through” of operating areas (to be determined).
The results of the most recent self-assessment against the level 2 AI-PS protocols
shall be provided by the Facility Audit Coordinator to the Audit Team Leader one (1)
working week before the start of the audit (for AI-PS Elements in scope of this audit).
The asset shall provide the necessary personal protective equipment (PPE), including
hard hats, hearing protection, safety glasses, personal H2S gas monitors and escape
sets, where required.
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The schedule will include adequate time set aside for the audit team at the facility for
clarification and draft report writing.
Event
Date
Complete the self-assessment against the level 2 AI-PS
protocols.
DD MMM YYYY
Finalise schedule of audit with Audit Lead.
DD MMM YYYY
Issue of pre-read.
DD MMM YYYY
Audit team briefing on ToR, audit methodology and reporting.
DD MMM YYYY
Opening meeting. Lead Auditor and Facility Audit Coordinator
presentations.
DD MMM YYYY
Muscat office interviews.
DD MMM YYYY
Audit team travels to interior (FLIGHT / LOGISTICS DETAILS).
DD MMM YYYY
Interior interviews.
DD MMM YYYY
Field work.
DD MMM YYYY
Draft audit findings and interior feedback.
DD MMM YYYY
Audit team travels to Muscat (FLIGHT / LOGISTICS DETAILS).
DD MMM YYYY
Peer review.
DD MMM YYYY
Review agreed findings with Facility Audit Coordinator and
Auditee.
DD MMM YYYY
Close-out meeting.
DD MMM YYYY
Draft report issued to auditee.
DD MMM YYYY
Responses from auditee to be returned to audit team.
DD MMM YYYY
Final report issued.
DD MMM YYYY
Methodology
The audit will be conducted using the PDO HSE Audit methodology summarized below.
Findings shall be classified and the implementation of AI-PS Elements assessed in
accordance with the criteria shown below.
To facilitate the efficient and effective execution of the audit, it is required that the selfassessment against the level 2 AI-PS protocols, Plant Operating Manual and
Operations HSE Case shall be forwarded or made accessible to Audit Team Leader at
least one (1) week prior to the audit (can be in electronic form, via website / LiveLink
access or hard copy). This will allow a review of the auditee’s arrangements and
enable set-up of the audit to ensure focus on the areas likely to represent the highest
risk to the business. The list of required documents is included later in these Terms of
Reference.
The methodology will use a “risk-based” approach and a general auditing approach in
line with good industry practice. Team members will gather information by field
observation, through interviews and including checks of hardware and documentation.
Audit evidence will be based upon sampling of the available information and therefore
should not be considered all-inclusive or exhaustive. Conscientious efforts will be
made to verify findings and to confirm the validity of recommended actions. Where
judgment is required, the result will be determined by consensus within the audit team.
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Audit Findings Classification
Classification of the audit findings shall be in accordance with the Rating Level table.
All findings are to be classified based upon the professional judgment of the audit
team. The primary criterion for rating each finding is the adequacy of the control for the
risk against the expectation set in the relevant PDO AI-PS Element Guides (GU-668).
Weakness Level
Definition
Serious (S)
The finding is likely to cause a high undesirable effect on the
achievement of PDO’s objectives, therefore warranting
immediate reporting to senior management e.g. AD level.
High (H)
The finding is likely to cause a high undesirable effect on the
achievement of one of PDO’s objectives, warranting reporting to
the auditee’s management.
Medium (M)
The finding is likely to cause a measurable undesirable effect on
the achievement of one of PDO’s objectives.
Low (L)
The weakness is unlikely to have a measurable impact on PDO’s
objectives, but its correction would enhance the risk based
control framework.
Overall Assessment of AI-PS Elements and Audit Rating
No audit opinion will be provided. Assessments of the implementation of the AI-PS
Elements in line with the PDO AI-PS Element Guides (GU-668) will be indicated by
reference to three possible categories:
Controls Acceptable
None, or a few Low and/or Medium rated findings are reported which indicate that
a “once-off” rather than process or system structural weaknesses is present or
that general enhancement of the controls, process, or system framework is not
needed (note: few = 2 or less).
Controls Need Improvement
Some Medium and / or one or more High rated findings are reported which
indicate a weakness in key controls / barriers or in a part of the process or system
structural framework (note: some = 3 or more).
Controls Need Major Improvement
Three or more High and/or one or more Serious rated findings are reported
indicating failures in key controls / barriers or across a significant part of the
process or system structural framework.
A further qualitative description will be provided as part of the Summary and
Conclusions, to summarise the overall outcome and highlighting the AI-PS Elements
where findings are identified. This will include a table that depicts a reference to each
finding and the control acceptability assessment for each AI-PS Element.
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During the audit the audit team may come across weaknesses in an AI-PS Element,
which have already been identified by the auditee in the self-assessment. In some of
these cases the auditee may be able to claim ‘work-in-progress’ (WIP) when the
following criteria have been met:
 Relevant issues and actions are identified and documented prior to the start of
the audit.
 For these issues and actions an implementation plan was already in place prior
to the start of the audit with milestones set and resources allocated together
with evidence of implementation having begun.
 During the audit, the follow-up process was found to be satisfactory, taking into
account the track record of the business in closing out action items.
 Interim mitigations to control the risk area are in place, and deemed effective by
the audit team.
Where testing by the audit team proves that the above criteria can be met, reliance can
be placed on the existing process. No specific findings shall be raised for these issues
in the audit report, however, due reference will be made in the executive summary of
the audit report as to the degree of reliance that was placed on the. Such issues will
also not have major impacts on the opinion. Where one of the above criteria has not
been met, reliance cannot be placed on the process. Another finding will therefore be
raised to ensure that relevant actions are taken. The audit opinion will take such audit
findings into account.
Report
The draft audit report shall undergo a peer review prior to the discussion with the
auditee.
The team will present the audit results to the auditee and their management at the
conclusion of the audit. This closing meeting or presentation shall be conducted at the
end of the audit or as pre-arranged between the auditee and the Audit Team Leader.
The purpose of this meeting is to formally communicate the findings and the
assessment of the acceptability of controls to the auditee and the management team
and to ensure clarity of understanding. The findings, associated classifications, and
acceptability of controls shall be considered “frozen” and only editorial changes allowed
may be considered. The Audit Team Leader may also be asked by the auditee to
present the audit results to wider audience.
Within seven (7) days of the audit conclusion, the Audit Team Leader shall send a
“Draft for Review” copy of the audit report to the Auditee. The Auditee will work with
his/her organisation to define the most appropriate way to address the findings and
recommendations, assign the action party and determine the planned completion date.
The Auditee shall have 14 days to comment and to complete the “Action”, “Action
Party” and “Due Date” fields for each of the findings / recommendations. The Audit
Team Leader will review the actions and timings proposed by the site and will request
clarification if required to ensure that actions do address the audit findings. When
substantial agreement has been reached on the contents of the report, the report will
become Final.
Where agreement on findings or appropriate actions to address findings and/or
recommendations cannot be reached, the Audit Team Leader may discuss with the
next level of management of the auditee’s business and agree a forward plan to
resolve the issue. In cases where resolution between the auditor and auditee /
auditee’s line management cannot be reached, they shall be escalated to UEOD. If the
disputed area cannot be resolved, the Audit Team Leader view will prevail although the
auditee will have the right to insert a management comment to provide his/her point of
view (on the appropriateness of actions only).
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Once the report is completed, it shall be distributed as agreed with the auditee as
shown in these Terms of Reference. The Facility Audit Coordinator will input the action
items in Fountain IMPACT and monitor for completion by the action parties and report
to PDO TDG.
Logistics
The auditee shall provide the following facilities:
 The necessary personal protective equipment (PPE) – request will be submitted
by Audit Leader.
 IT authorization for audit team to access local data files.
 A lockable office with sufficient space, desk/table area, and chairs for the audit
team and sufficient wall space to display several flipcharts.
 Flip chart holder with paper, ink markers, and 3M type “post-it” or “sticky pads”.
 A stapler with staples, tape (scotch and masking).
 Computer connection to electronic system which documents are stored (e.g.,
local intranet, shared folders).
 Computer projector (“beamer”).
 Telephone service.
 At least two internet connections via server.
 Access to system printers (provide printer number), copy machine, and fax
machine.
 Permission and permit (including gas testing as required) to take photographs
on site (i.e. primarily during the site visit).
AI-PS Documentation Request
The following documentation (preferable electronic copy or web site / LiveLink area)
shall be provided to the Audit Team Leader at least one (1) week prior to the start of
the audit. These documents will be reviewed in order to prioritise the audit on areas of
highest risk.
1. Self-assessment against the level 2 AI-PS protocols;
2. Plant Operating Manual; and
3. Operations HSE Case
Additional documentation may be requested during the audit process including PDO
procedures and asset business records relevant to the AI-PS self-assessment.
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Appendix 2 - Audit Working Paper (Example)
KEY RISK CONTROL AREA/COMPONENT: Emergency Preparedness and Response
RISK BASED CONTROL(s) / AI-PS EXPECTATIONS
CP 122-2.5
It is PDO’s responsibility to ensure those plans, procedures and resources are in place
to respond swiftly and efficiently to any emergency situation and to minimise any
consequential losses.
STATUS OF CONTROL (+/-)
Observations (current controls in place):

It was observed that the Contractors main office well laid out with suitable work
stations, information boards and comms systems in place. Checklist for each key
role observed.

It was reported that oil spills exercises tier 1, 2 and 3 were performed as per
MOSAG.

It was observed during a visit to the tug boats that ER musters and drill have been
carried out, evidence in the register and captains log. An exercise was carried out
on board to a satisfactory nature.

At the Power Station, the emergency contact number was last updated 23/2/2011.

Absorbent is available in laboratory to clean-up spills.

ER drill was managed with the main Contractor. Saw record for November 2011Feb 2012. Gap identified was input into a single action tracker managed by
Contractor.

Good housekeeping at the Power Plant Project Site with clear indication of
emergency escape routes.
Observations (gaps in controls):
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
Observations on ER in laboratory at Site: H2S alarm system last calibrated in
17/7/2009 with due date pasted on the panel as 11/1/10. No record available after
that. One detector (H2S detector #5) was at fault but no schematic to identify the
affected detector in the lab. No record available for last alarm testing for the H2S
Alarm. No drill done wrt H2S release and therefore, whether the H2S alarm which
is located outside the 3 labs (Oil, Water, Cement) can be heard by staff working in
lab is unknown.

Lab at Site. During the visit, could not locate spill recovery kit.

The lab is located within the overall office building. The drill is therefore together
with the office building which is mainly evacuation drill. No record of previous lab
emergency drill with scenario on lab chemical fire etc.

Two H2S monitors used by the lab staff at Site were outside their calibration period
(e.g. detector no. 0074 expired 23/6/2010). No register of H2S monitor calibration
records could be found.

General awareness level of lab staff at Site was inconsistent e.g. no detailed
knowledge of H2S levels found at different sites, requirements for use of BA sets,
escape sets, buddy system.

Fire extinguishers at the Power Station overdue their inspection date - due January
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
Fire extinguisher inspection frequency at Site is 6 months while in the frequency
other Sites is every 3 months.

Smoke detectors installed in the offices used by the Power Station Projects did not
work.
POTENTIAL FINDINGS
There are gaps in the preparedness to respond in case of emergencies at the lab.
There are also improvements for fire equipment maintenance. This was evidenced by

Overdue calibration of H2S monitors and alarms in the lab

Lack of spill recovery kit in lab

Emergency drills not covering relevant potential scenarios for the lab

Inconsistent identification of inspection dates of portable fire extinguisher
maintenance

Smoke detectors in Contractor office not working.
_____________________________________________________________________
Degree of weakness / materiality of flaw in control :
Is control completely missing or is flawed to extent that it is effectively not functioning?
No
Is a control in place but has a material flaw? Control is in place, but gaps exist.
Is there a gap likely to have a measurable undesirable impact on the achievement of
one of the entity’s HSE objectives and therefore warrants remedial actions to be taken.
_____________________________________________________________________
Rating: MEDIUM
_____________________________________________________________________
Cross checks:
To what sort of incident could such a gap in controls lead e.g. has a material flaw in
application of MOC for organization played a key contributory role in prior incident(s)
that could be classified in the RAM Yellow or RAM Red categories?
Or What does the auditee’s risk register rank as?
Does such a control gap warrant remedial actions to be taken in a short term time
frame with oversight of the follow-up of these actions at the level of Business
Leadership Team (i.e. MDC level)?
IMPLICATION(S)
Laboratories may not detect and respond to emergencies to make timely response if
the detectors, alarms are not in good calibration/ maintenance.
Confusion in fire extinguishers inspection status may leave the response.
RECOMMENDATION(S)
1. Identify safety critical elements including detectors and alarms in the laboratory and
include in SAP for maintenance and monitoring.
2. Evolve procedure for inspection, maintenance and identification of inspection
status tagging of portable fire extinguishers.
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Appendix 3 - Level 3 Assurance Plan (Example)
Element
PSEC
Jan
2
OSE1N
1
6
OSO22N
7
OSO1N
8
OSO22N
9
OSO14N
10
OSO4N
11
OSET4N
13
OSON
15
OSO1N
Feb
Mar
Apr
May
Jun
1
2
Jul
Aug
1
2
3
5
2
5
10
5
7
6
7
8
10
11
4
6
9
Dec
3
6
8
Nov
2
5
7
Oct
1
4
6
Sep
9
10
11
7
10
11
11
Notes to schedule:
1. Engineering TA-2 review of an engineering modification.
2. Sample check of critical drawings for a single process unit, e.g. PEFS, hazardous area
drawings, cause & effects, fire & gas causes & effects, area layouts, etc.
3. Sample check of completed “production” risk assessments (RA), e.g. job HSE plans
attached to permits, RA supporting temporary override of safeguarding systems, etc.
4. Sample check of completed “maintenance” RAs in FSR.
5. Sample check of a chapter from a Plant Operating Manual.
6. Level 3 PTW audit.
7. Hardware Barrier Verification of a single barrier.
8. Level 3 audit of EMC contractor.
9. Level 3 audit of ODC contractor.
10. Review of a completed FCP.
11. Level 3 Conduct of Operations audit (Top 10 Procedures).
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Appendix 4 - Typical Level 3 Production Operation Function
Audit.
Level 3 Audit Terms of Reference
The Audit Terms of Reference (ToR) shall be used in the initial stages of the Audit planning to
outline to the proposed Auditee(s) the scope and structure of the audit.
Level 3 Audit Workbook
The Level 3 Audit Workbook (Excel) is provided to enable the audit checklists and results to be
maintained in one location. The workbook is provided with a Title sheet and examples of the two
formats that are required to be used. The workbook shall contain all the elements of the audit to
provide one document.
Level 3 Audit Report
The Audit Report shall be used to relay back the findings, conclusions and recommendations of
the audit to the auditee(s) and follow-up coordinators.
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Appendix 5 - Process Safety Management Framework
The Center for Chemical Process Safety (CCPS) developed a Risk Based Process
Safety framework. The framework was organised into four pillars, which were further
made up of twenty elements. This appendix provides a summary of the expectations
set by the CCPS Guidelines for Risk Based Process Safety. The expectations may be
useful for a level 1 audit of PDO AI-PS management. The Company has developed
guidelines for each of these elements that translate the CCPS guidelines into
requirements in the PDO Corporate Management Framework. The PDO guidelines for
AI-PS are contained in GU-668.
Commit to Process Safety
To commit to process safety, facilities should focus on:
1.

Developing and sustaining a culture that embraces process safety

Identifying, understanding and complying with codes, standards, regulations,
and laws

Establishing and continually enhancing organizational competence

Soliciting input from and consulting with all stakeholders, including employees,
contractors, and neighbours
Process Safety Culture
Process safety culture is defined as the combination of group values and behaviours
that determine the manner in which process safety is managed.
Maintain a dependable practice:

Establish Process Safety as a core value

Provide strong leadership

Establish and enforce high standards of performance

Document the process safety emphasis and approach
Develop and implement a sound culture:

Maintain a sense of vulnerability

Empower individuals to successfully fulfil their safety responsibilities

Defer to expertise

Ensure open and effective communications

Establish a questioning / learning environment

Foster mutual trust

Provide timely response to process safety issues and concerns
Monitor and guide the culture:

2.
Provide continuous monitoring of performance
Compliance with Standards
The standards system addresses both internal and external standards; national and
international codes and standards; and local, state, and federal regulations and laws.
The system makes this information easily and quickly accessible to potential users.
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Maintain a dependable practice:

Ensure consistent implementation of the standards system

Identify when standards compliance is needed

Involve competent personnel

Ensure that standards compliance practices remain effective
Conduct compliance work activities:

Provide appropriate inputs to standards activities

Conduct compliance assurance activities

Determine compliance status periodically as required and provide a status
report to management

Review the applicability of standards as new information or changes arise
Follow through on decisions, actions and use of compliance results
3.

Update compliance documents and reports as needed

Communicate conformance or submit compliance assurance records to the
appropriate external entity

Maintain element work records
Process Safety Competency
Developing and maintaining process safety competency encompasses three interrelated
actions: (1) continuously improving knowledge and competency, (2) ensuring that
appropriate information is available to people who need it, and (3) consistently applying
what has been learned.
Maintain a dependable practice:

Establish objectives

Appoint a chairman

Identify corollary benefits

Promote a learning organization
Execute activities that help maintain and enhance process safety competency
Page 31

Appoint technology stewards

Document knowledge

Ensure that information is accessible

Provide structure

Push knowledge to appropriate personnel

Apply knowledge

Update information

Promote person-to-person contact

Plan personal transitions

Solicit knowledge from external sources
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Evaluate and share results
4.

Evaluate the utility of existing efforts

Solicit needs from operating units
Workforce Involvement
Workforce involvement provides a system for enabling the active participation of
company and contractor workers in the design, development, implementation, and
continuous improvement of the RBPS management system.
Maintain a dependable practice:

Develop the basic framework or standards for the workforce participation plan at
the corporate level

Define, subject to risk-based considerations, classes of issues that can be
resolved by workers without management involvement

Provide for substantive workforce participation in the creation or revision of
safety policies and procedures, and the establishment of safety goals and plans

Create positions for safety champions, staffed by workforce volunteers, to serve
in an advisory and mentoring role

Provide training on hazard identification and basic risk assessment principles to
all operators and maintenance personnel
Conduct work activities:
Page 32

Institute a worker job safety observation program

Implement a suggestion submission and response program independent of any
particular RBPS element

Include personnel from all levels of the organization in a regularly scheduled
program of field safety and housekeeping inspections

Implement a program of informal what-if exercises, such as table top drills, as
part of the process safety training program

Conduct an annual process technology or process safety school developed and
taught with significant workforce involvement

Institute a formal mentoring program in which senior, experienced workers
assist in the development of less experienced personnel

Assign experienced operators and maintenance personnel to project design
teams

Conduct periodic offsite meetings, during which workers from all levels
collaboratively identify potential opportunities for system improvements

Use a web-based electronic survey to collect feedback from manufacturing and
research facilities

When communicating safety messages or safety policies, include a convenient
way for the reader to provide feedback

Form functional teams for relevant Risk Based Process Safety (RBPS)
elements, with worker representation from all levels

Reassign selected workers from their normal duties and dedicate them to
accomplishing a key RBPS task

Budget time into work schedules to allow workforce members to fulfil formalized
workforce involvement activities
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
Establish and adhere to schedules for senior staff to spend time in work areas

Use a quality circle approach to addressing RBPS management system
problems

Establish inter-facility networks to address common issues

Strive to motivate a broad range of participation
Monitor the system for effectiveness
5.

Involve the workforce in identifying suitable RBPS metrics and in monitoring and
communicating this information to management

Maintain auditable records documenting workforce involvement activities

Conduct periodic surveys to monitor worker attitudes and to solicit inputs
Stakeholder Outreach
Stakeholder outreach is a process for (1) seeking out individuals or organizations that
can be or believe they can be affected by company operations and engaging them in a
dialogue about process safety, (2) establishing a relationship with community
organizations, other companies and professional groups, and local, state, and federal
authorities, and (3) providing accurate information about the company and facility’s
products, processes, plans, hazards, and risks.
Maintain a dependable practice:



Ensure consistent implementation
Involve competent personnel
Keep practices effective
Identify communication and outreach needs:


Identify relevant stakeholders
Define appropriate scope
Conduct communication / outreach activities:





Identify appropriate communication pathways
Develop appropriate communication pathways
Develop appropriate communication tools
Share appropriate information
Maintain external relationship
Follow through on commitments and actions:

Follow up commitments to stakeholders and receive feedback

Share stakeholder concerns with management

Document outreach encounters
Understand Hazards and Risk
To understand hazards and risk, facilities should focus on:
Page 33

Collecting, documenting, and maintaining process safety knowledge

Conducting hazard identification and risk analysis studies
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Process Knowledge Management
The knowledge element primarily focuses on information that can easily be recorded in
documents, such as (1) written technical documents and specifications, (2) engineering
drawings and calculations, (3) specifications for design, fabrication, and installation of
process equipment, and (4) other written documents such as material safety data
sheets (MSDSs).
Maintain a dependable practice:

Ensure consistent implementation

Define the scope

Thoroughly document chemical reactivity and incompatibility hazards
Catalogue process knowledge in a manner that facilitates retrieval:

Make information available and provide structure

Protect knowledge from inadvertent loss

Store calculations, design data, and similar information in central files

Document information in a user-friendly manner
Protect and update process knowledge:

Control or limit access to out-of-date documents

Ensure accuracy

Protect against inadvertent change

Protect against physical (or electronic) removal or misfiling

Support efforts to properly manage change
Use process knowledge:
7.

Ensure awareness

Ensure that process knowledge remains useful
Hazards and Effects Management Process (Hazard Identification
and Risk Analysis in CCPS Guide)
Hazards and Effects Management Process (HEMP) is a collective term that
encompasses all activities involved in identifying hazards and evaluating risk at facilities,
throughout their life cycle, to make certain that risks to employees, the public, or the
environment are consistently controlled within the organization’s risk tolerance.
Maintain a dependable practice:







Page 34
Document the intended risk management system
Integrate HEMP activities into the life cycle of projects or processes
Clearly define the analytical scope of HEMPs and assure adequate coverage
Determine the physical scope of the risk system
Involve competent personnel
Make consistent risk judgments
Verify that HEMP practices remain effective
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Identify hazards and evaluate risks:





Gather and use appropriate data to identify hazards and evaluate risks
Select appropriate HEMP methods
Ensure that HEMP reviewers have appropriate expertise
Perform risk activities to the appropriate level of technical rigor commensurate
with the life cycle stage and the available information
Prepare a thorough risk assessment report
Assess risks and make risk-based decisions:


Apply the risk tolerance criteria
Select appropriate risk control measures
Follow through on the assessment results:






Communicate important results to management
Document the residual risk
Resolve recommendations and track completion of actions
Communicate results internally
Communicate results externally
Maintain risk assessment records
Manage Risk
To manage risk, facilities should focus on:









Page 35
Developing written procedures that (1) describe how to safely start up, operate,
and shut down processes, (2) address other applicable operating modes, and
(3) provide written instructions that operators can execute when they encounter
process upsets / unsafe conditions.
Implementing an integrated suite of safe work policies, procedures, permits, and
practices to control maintenance and other non-routine work.
Executing work activities to ensure that equipment is fabricated and installed in
accordance with specifications, and that it remains for service over its entire life
cycle.
Managing contractors, and evaluating work performed by contractors, to ensure
that the associated risks are acceptable; ensuring that contractors are not
exposed to unrecognized hazards or undertake activities that present unknown
or intolerable risk.
Providing training and conducting related activities to ensure reliable human
performance at all levels of the organization.
Recognizing and managing changes.
Ensuring that units, and the people who operate them, are properly prepared for
start-ups.
Maintaining a very high level of human performance, particularly among
operators, maintenance personnel, and others whose actions directly affect
process safety.
Preparing for and managing emergencies.
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Plant Operating Procedures (Operating Procedures in CCPS Guide)
Plant operating procedures are written instructions (including procedures that are stored
electronically and printed on demand) that (1) list the steps for a given task and (2)
describe the manner in which the steps are to be performed.
Maintain a dependable practice:



Establish management controls
Control procedure format and content
Control documents
Identify what operating procedures are needed:



Conduct a task analysis
Determine what procedures are needed and their appropriate level of detail
Address all operating modes
Develop procedures:











Use an appropriate format
Ensure that the procedures describe the expected system response, how to
determine if a step or task has been done properly, and possible consequences
associated with errors or omissions
Address safe operating limits and consequences of deviation from safe
operating limits
Address limiting conditions for operation
Provide clear, concise instructions
Supplement procedures with checklists
Make effective use of pictures and diagrams
Develop written procedures to control temporary or non-routine operations
Group the tasks in a logical manner
Interlink related procedures
Validate procedures and verify that actual practice conforms to intended
practice
Use the procedures to improve human performance:



Use the procedures when training
Hold the organization accountable for consistently following procedures
Ensure that procedures are available
Ensure that procedures are maintained:



Page 36
Manage changes
Correct errors and omissions in a timely manner
Periodically review all operating procedures
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Permit To Work (Safe Work Practices in CCPS Guide)
Permit To Work (PTW) fills the gap between operating procedures and maintenance
procedures. Safe work practices help control hazards and manage risk associated with
non-routine work.
Maintain a dependable practice:




Define the scope
Specify when in the facility’s life cycle the safe work procedures apply
Ensure consistent implementation
Involve competent personnel
Effectively control non-routine work activities:





10.
Develop safe work procedures, permits, checklists, and other written standards
Train employees and contractors
Control access to particularly hazardous areas
Enforce the use of safe work procedures, permits, and other standards
Review completed permits
Technical Integrity (Asset Integrity and Reliability in CCPS Guide)
Technical integrity is the systematic implementation of activities, such as inspections
and tests necessary to ensure that important equipment will be suitable for its intended
application throughout its life.
Maintain a dependable practice:






Develop a written program description / policy
Determine the scope of the asset integrity elements
Base design and ITPM tasks on standards
Involve competent personnel
Update practices based on new knowledge
Integrate the asset integrity element with other goals
Identify equipment and systems that are within the scope of the asset integrity program
and assign ITPM tasks:



Identify equipment / systems for inclusion in the asset integrity element
Develop an ITPM plan
Update the ITPM plan when equipment conditions change
Develop and maintain knowledge, skills, procedures, and tools:




Develop procedures for inspection, test, repair, and other maintenance activities
Train employees and contractors
Ensure that inspectors hold appropriate certifications
Provide the right tools
Ensure continued fitness for purpose:
Page 37



Conduct initial inspections and tests as part of plant commissioning
Conduct tests and inspections during operations
Execute calibration, adjustment, preventative maintenance, and repair activities



Plan, control, and execute maintenance activities
Ensure the quality of repair parts and maintenance materials
Ensure that overhauls, repairs, and tests do not undermine safety
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Address equipment failures and deficiencies:




Promptly address conditions that can lead to failure
Review test and inspection reports examine results to identify broader issues
Investigate chronic failures using a structured methodology
Plan maintenance and repair activities
Analyze data:





11.
Collect and analyze data
Adjust inspection frequencies and methods
Conduct additional inspections or tests as needed
Plan replacements or other corrective actions
Archive data
Contractor Management
Contractor management is a system of controls to ensure that contracted services
support both safe facility operations and the company’s process safety performance
goals.
Maintain a dependable practice:




Ensure consistent implementation
Identify when contractor management is needed
Involve competent personnel
Ensure that practices remain effective
Conduct element work activities:




Appropriately select contractors
Establish expectations, roles, and responsibilities for safety
implementation and performance
Ensure that contractor personnel are properly trained
Fulfil company responsibilities with respect to safety performance
program
Monitor the contractor management system for effectiveness


12.
Audit the contractor selection process
Monitor and evaluate contractor safety performance
Training and Performance Assurance
Training is practical instruction in job and task requirements and methods. Performance
assurance is the means by which workers demonstrate that they have understood the
training and can apply it in practical situations.
Maintain a dependable practice:



Page 38
Define roles and responsibilities
Validate program effectiveness
Control documents
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Identify what training is needed:





Conduct a job / task analysis
Determine minimum requirements (or essential elements) for job candidates
Determine what training is needed
Group training into logical programs
Manage changes
Provide effective training:




Develop or procure training materials
Consider timing
Interweave related topics
Ensure that training is available
Monitor worker performance:



13.
Qualify workers initially
Test workers periodically
Review all qualification requirements periodically
Management of Change
The MOC element helps ensure that changes to a process do not inadvertently
introduce new hazards or unknowingly increase risk of existing hazards.
Maintain a dependable practice:



Establish consistent implementation
Involve competent personnel
Keep MOC practices effective
Identify potential change situations:


Define the scope of the MOC system
Manage all sources of change
Evaluate possible impacts:



Provide appropriate input information to manage changes
Apply appropriate technical rigor for the MOC review process
Ensure that MOC reviewers have appropriate expertise and tools
Decide whether to allow the change:


Authorize changes
Ensure that change authorizers address important issues
Complete follow-up activities:




Page 39
Update records
Communicate changes to personnel
Enact risk control measures
Maintain MOC records
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Operational Readiness
The readiness element ensures that shut down processes are verified to be in safe
condition for re-start.
Maintain a dependable practice:





Ensure consistent implementation
Determine types of and triggers for the readiness practice
Determine the scope of readiness reviews
Involve competent personnel
Ensure that readiness practices remain effective
Conduct appropriate readiness reviews as needed:





Provide appropriate inputs
Involve appropriate resources and personnel
Apply an appropriate work process
Perform element work in a diligent manner
Create element work products
Make startup decisions based upon readiness results:


Consider important issues affecting the startup
Communicate decisions and actions from the readiness review
Follow through on decisions, actions, and use of readiness results:



15.
Enact risk control measures
Update process safety knowledge and records
Maintain element work records
Conduct of Operations
Conduct of operations institutionalizes the pursuit of excellence in the performance of
every task and minimize variations in performance.
Maintain a dependable practice:



Define roles and responsibilities
Establish standards for performance
Validate program effectiveness
Control operations activities:









Page 40
Follow written procedures
Follow safe work practices
Use qualified workers
Assign adequate resources
Formalize communications between workers
Formalize communications between shifts
Formalize communications between work groups
Adhere to safe operating limits and limiting conditions for operations
Control access and occupancy
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Control the status of systems and equipment:






Formalize equipment / asset ownership and access protocols
Monitor equipment status
Maintain good housekeeping
Maintain labelling
Maintain lighting
Maintain instruments and tools
Develop required skills / behaviours:





Emphasize observation and attention to detail
Promote a questioning / learning attitude
Train workers to recognize hazards
Train workers to self-check and peer-check
Establish standards of conduct
Monitor organizational performance:





16.
Maintain accountability
Strive to continuously improve
Maintain fitness for duty
Conduct field inspections
Correct deviations immediately
Emergency Management
Emergency management includes (1) planning for possible emergencies, (2) providing
resources to execute the plan, (3) practicing and continuously improving the plan, (4)
training or informing employees, contractors, neighbours, and local authorities on what
to do, how they will be notified, and how to report an emergency, and (5) effectively
communicating with stakeholders in the event an incident does occur.
Maintain a dependable practice:



Develop a written program
Designate an owner and define roles and responsibilities
Involve competent personnel
Prepare for emergencies:












Page 41
Identify accident scenarios based on hazards
Select planning scenarios
Plan defensive response actions
Plan offensive response actions
Develop written emergency response plans
Provide physical facilities and equipment
Maintain / test facilities and equipment
Determine when unit operator response is appropriate
Train ERT members
Plan communications
Inform and train all personnel
Periodically review emergency response plans
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Periodically test the adequacy of plans and level of preparedness






Conduct emergency evacuation and emergency response drills
Conduct tabletop exercises
Practice crisis communication
Critique exercises, drills, and actual responses
Conduct assessments and audits
Address findings and recommendations
Learn from Experience
To learn from experience, facilities should focus on:





17.
Investigating incidents that occur at the facility to identify and address the root
causes.
Applying lessons from incidents that occur at other facilities within the company
and within the industry.
Measuring performance and striving to continuously improve in areas that have
been determined to be risk significant.
Auditing RBPS management systems as well as the performance of work
activities that make up the management system.
Holding periodic management reviews to determine if the management systems
are working as intended and if the work activities are helping the facility
effectively manage risk.
Incident Investigation
Incident investigation is a process for reporting, tracking, and investigating incidents that
includes (1) a formal process for investigating incidents, including staffing, performing,
documenting, and tracking investigations of process safety incidents.
Maintain a dependable incident reporting and investigation practice:




Implement the program consistently across the company
Define an appropriate scope for the incident investigation element
Involve competent personnel
Monitor incident investigation practices for effectiveness
Identify potential incidents for investigation:



Monitor all sources of potential incidents
Ensure that all incidents are reported
Initiate investigations promptly
Use appropriate techniques to investigate incidents







Page 42
Interface with the emergency management element
Use effective data collection methods
Use appropriate techniques for data analysis
Investigate causes to an appropriate depth
Demand technical rigor in the investigation process
Provide investigation personnel with appropriate expertise and tools
Develop effective recommendations
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Document incident investigation results:


Prepare incident investigation reports
Provide clear linking between causes and recommendations
Follow through on results of investigations:




Resolve recommendations
Communicate findings internally
Communicate findings externally
Maintain incident investigation records
Trend data to identify repeat incidents that warrant investigation:


18.
Log all reported incidents
Analyze incident trends
Measurement and Metrics
This element addresses which indicators to consider, how often to collect data, and
what to do with the information to help ensure responsive, effective RBPS management
system operations.
Maintain a dependable practice:





Establish consistent implementation
Determine triggers for metrics collection and reporting
Ensure that the scope of the metrics is appropriate
Involve competent personnel
Keep metrics practices effective
Conduct metrics acquisition:


Implement appropriate element metrics
Collect and refresh metrics
Summarize and communicate metrics in a useful format

19.
Use metrics element to improve RBPS elements
Auditing
The audits element is intended to evaluate whether management systems are
performing as intended.
Maintain a dependable practice:



Ensure consistent implementation
Involve competent personnel
Identify when audits are needed
Conduct element work activities:
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Page 43
Prepare for the audit
Determine the audit scope and schedule
Assemble the team
Assign responsibilities
Gather advanced information
Plan onsite activities
Conduct the audit
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
Revision: 2.0
Effective: May-12
Document the audit
Address audit findings and recommendations
Use audits to enhance RBPS effectiveness:


20.
Monitor RBPS maturation over time for each facility
Share best practices
Management Review and Continuous Improvement
Management review is the routine evaluation of whether management systems are
performing as intended and producing the desired results as efficiently as possible.
Maintain a dependable practice:



Define roles and responsibilities
Establish standards for performance
Validate program effectiveness
Conduct review activities:








Prepare for the review
Determine the review scope
Schedule the review
Gather information
Prepare a presentation
Conduct the review
Document the review
Address review findings / recommendations
Monitor organizational performance:
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Page 44
Strive to continuously improve
Conduct field inspections
PR-1712 - 'AI-PS Assurance' Procedure
Printed 12/02/16
The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED.
Petroleum Development Oman LLC
Revision: 2.0
Effective: May-12
Appendix 6 - Abbreviations
The following abbreviations are used in this Procedure.
AI-PS
Asset Integrity – Process Safety
AIPSALT
Asset Integrity & Process Safety Action Leadership Team
AWP
Audit Working Paper;
CCPS
Center for Chemical Process Safety
HSE
Health Safety and Environment
KPI
Key Performance Indicator
OLT
Operations Leadership Team
PPE
Personal protection Equipment
RASCI
Responsible, Accountable, Support, Consult, Inform
RBPS
Risk Based Process Safety
TDG
Technical Directors Group
TOR
Terms Of Reference
Page 45
PR-1712 - 'AI-PS Assurance' Procedure
Printed 12/02/16
The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED.
Petroleum Development Oman LLC
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Effective: May-12
Appendix 7 – Reference Material
The following list contains only the main documents of related to this procedure.
Codes of Practice

CP-107 - Corporate Management Framework - CoP

CP-114 - Maintenance & Integrity Management Code of Practice

CP-115 - Operate Surface Product Flow Assets - CoP

CP-118 - Well Lifecycle Integrity CoP

CP-122 - HSE Management System

CP-206 - Management of Change - CoP
Procedures

PR-1000 - Operations Handover Procedure

PR-1001a - Facility Change Proposal Procedure

PR-1001c - Temporary Override of Safeguarding System Procedure

PR-1001e - Operations Procedure Temporary Variance

PR-1005 - Maintenance and Inspection Activity Variance Control Procedure

PR-1010 - Pipeline Derating Procedure

PR-1023 - Automation Systems Software Management Procedure

PR-1029 - Competence Assessment & Assurance

PR-1072 - Preparations and Management of Operations Procedures

PR-1073 - Gas Freeing, Purging & Leak Testing of Process Equipment

PR-1076 - Isolation of Process Equipment Procedure

PR-1077 - Preparation of Static Equipment for Internal Maintenance and Inspection

PR-1078 - Hydrogen Sulphide Management Procedure

PR-1079 - Gas Freeing and Purging of Tanks Procedure

PR-1081 - The Buddy System Procedure

PR-1086 - Locked Valve and Spectacle Blind Control

PR-1098 - Well Activity Co-ordination & Control Procedure

PR-1154 - Gas Testing Procedure

PR-1159 - Commissioning and Start-up

PR-1172 - Permit to Work Procedure
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PR-1248 - Functional Criticality Assessment Procedure

PR-1960 - Control of Portable Temporary Equipment

PR-1961 - Process Leak Management
Guidelines
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Page 46
GU-668 - AI-PS Elements Guide
PR-1712 - 'AI-PS Assurance' Procedure
Printed 12/02/16
The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED.
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