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. Petroleum Development Oman LLC Revision: 2.0 Effective: May-12 This page was intentionally left blank Page 2 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 i Revision: 2.0 Effective: May-12 Document Authorisation Authorised For Issue – May 2012 Page 3 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 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 Page 4 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 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 Page 5 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 1 Introduction 1.1 Background Revision: 2.0 Effective: May-12 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. Page 6 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 1.4 Revision: 2.0 Effective: May-12 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 Page 7 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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 Page 8 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 2.1 Revision: 2.0 Effective: May-12 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: Page 9 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. 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 2.2 Revision: 2.0 Effective: May-12 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. Page 10 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. Page 11 C S R S I I PR-1712 - 'AI-PS Assurance' Procedure I Printed 12/02/16 The controlled version of this CMF Document resides online in Livelink®. Printed copies are UNCONTROLLED. Revision: 2.0 Effective: May-12 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 Petroleum Development Oman LLC 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: Page 12 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. 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. 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 3.1.4 Revision: 2.0 Effective: May-12 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). Page 14 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. 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 o Revision: 2.0 Effective: May-12 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 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. Page 17 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. 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 Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. 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 3.2.3 Revision: 2.0 Effective: May-12 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. 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. Page 20 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 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. Page 21 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. Page 22 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 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. Page 23 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 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). Page 24 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 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. Page 25 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 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): Page 26 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 2011. 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 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. Page 27 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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). Page 28 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 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. Page 29 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. Revision: 2.0 Effective: May-12 Petroleum Development Oman LLC 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. Page 30 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 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 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 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 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 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 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 6. Revision: 2.0 Effective: May-12 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 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 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. 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 8. Revision: 2.0 Effective: May-12 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 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 9. Revision: 2.0 Effective: May-12 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 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 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 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 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 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 14. Revision: 2.0 Effective: May-12 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 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 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 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 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 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 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: 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 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 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: 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 Revision: 2.0 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 PR-1248 - Functional Criticality Assessment Procedure PR-1960 - Control of Portable Temporary Equipment PR-1961 - Process Leak Management Guidelines 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.