EI - 2010 - High Level Framework PSM
EI - 2010 - High Level Framework PSM
EI - 2010 - High Level Framework PSM
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
1st edition
December 2010
Published by
ENERGY INSTITUTE, LONDON
The Energy Institute is a professional membership body incorporated by Royal Charter 2003
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The Energy Institute (EI) is the leading chartered professional membership body supporting individuals and organisations across the energy
industry. With a combined membership of over 13 500 individuals and 300 companies in 100 countries, it provides an independent
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international industry with information and guidance on key current and future issues.
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This publication has been produced as a result of work carried out within the Technical Team of the EI, funded by the EI’s Technical Partners.
The EI’s Technical Work Programme provides industry with cost-effective, value-adding knowledge on key current and future issues
affecting those operating in the energy sector, both in the UK and internationally.
The EI gratefully acknowledges the financial contributions towards the scientific and technical programme
from the following companies
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The information contained in this publication is provided for general information purposes only. Whilst the Energy Institute and the
contributors have applied reasonable care in developing this publication, no representations or warranties, express or implied, are made
by the Energy Institute or any of the contributors concerning the applicability, suitability, accuracy or completeness of the information
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
CONTENTS
Page
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 Development approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.2 Scope and application . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Annexes:
Annex A Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
A.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
A.2 Glossary of abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Annex B References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
iii
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
"Controlling risks within major hazard enterprises requires a robust process safety management
system, driven forward by high standards of leadership and supported by effective feedback
mechanisms to show the status of critical control measures. The value of this guidance produced
by the Energy Institute is that it sets out a clear framework on which to develop and implement a
process safety mangement system and from which effective 'on the ground' control measures can be
derived and maintained. Lessons from recent major incidents both in the UK and internationally show
in very stark terms the costs of getting process safety management wrong and I would encourage
you to apply those lessons to your own organisation by the adoption and maintenance of a robust
process safety management system."
Gordon Macdonald
Director - Hazardous Installations Directorate
Health and Safety Executive
iv
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
FOREWORD
Process safety management (PSM) is a major issue for the energy industry, with many organisations
looking to adopt a more holistic and systematic approach to assuring the integrity of their
operations.
The Energy Institute (EI) Process Safety Committee (PSC) identified a benefit in promoting a
common high-level framework for PSM across the energy industry sectors. EI High level framework
for process safety management ('PSM framework') provides a simple and systematic approach
suitable for organisations large and small across the energy industry sectors, defining the key things
organisations need to get right in order to assure the integrity of their operations incorporating
technical, maintenance, operational, and human and organisational factors.
EI PSM framework provides a consistent approach that should help organisations seeking efficient
development and implementation approaches to achieve effective PSM. It is intended to be applicable
to both large and small organisations in the worldwide energy industry sectors from upstream
production through to power distribution, as well as kindred industries like chemicals; however the
depth of application should vary in order to be applicable to the scope and complexity of their
operations.
EI PSM framework is not intended to replace existing process safety or health, safety and environmental
management systems (HS&EMSs). It sets out what should be covered by an existing management
system (MS) and as such provides a benchmark for good practice. In cases where an organisation does
not have a process safety management system (PSMS), EI PSM framework provides a design basis for
its development. It is also intended to provide a common basis for benchmarking of PSMSs.
Focus areas These set out the key high level components of EI PSM framework.
Elements Within each of the focus areas are a number of elements which set out the key
aspects of the operation that organisations need to get right in order to assure their
integrity.
Expectations Within each of the elements the expectations define what organisations need to get
right in order to meet the intent of each element.
Whilst there are other MSs that cover process safety, a key benefit of EI PSM framework is that
it has been developed by the energy industry for use by energy industry sectors, capturing and
incorporating learnings from people with practical experience of developing and implementing PSM
as part of an integrated MS. It also benefited from extensive stakeholder input and consultation
during its development.
For further information regarding the EI's PSM activities, see www.energyinst.org/psm-framework.
The information contained in this publication is provided for general information purposes only.
Whilst the Energy Institute and the contributors have applied reasonable care in developing this
publication, no representations or warranties, express or implied, are made by the Energy Institute
or any of the contributors concerning the applicability, suitability, accuracy or completeness of the
information contained herein and the Energy Institute and the contributors accept no responsibility
whatsoever for the use of this information. Neither the Energy Institute nor any of the contributors
shall be liable in any way for any liability, loss, cost or damage incurred as a result of the receipt or
use of the information contained herein.
Suggested revisions are invited and should be submitted through the Technical Department, Energy
Institute, 61 New Cavendish Street, London, W1G 7AR, e: technical@energyinst.org
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the licence terms and conditions. It must not be forwarded to, or stored or accessed by, any unauthorised user. Enquiries: e: pubs@energyinst.org.uk t: +44 (0)207 467 7100
HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
ACKNOWLEDGEMENTS
EI High level framework for process safety management was commissioned by the Energy Institute
(EI) Process Safety Committee (PSC) and developed by a sub-group comprising:
The Institute wishes to record its appreciation to those that participated in one or more stakeholder
workshops:
The following are acknowledged for commenting on the draft for consultation of this publication:
Peter Gedge BP
John Henderson CB&I Lummus
Marc McBride Centrica
Chris Venn Chevron
Dr David Firth Chilworth Group
David Bleakley ConocoPhillips
David Athersmith Consultant
vi
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
In addition, members of EI PSC are acknowledged for providing technical direction in this project,
in particular in a special meeting to discuss and review the technical comments on the draft for
consultation of this publication:
vii
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
1 INTRODUCTION
The Energy Institute (EI) Process Safety Committee (PSC) identified a benefit in promoting
a common high-level framework for process safety management (PSM) across the energy
industry sectors.
Process safety is a blend of engineering and management skills focused on preventing
catastrophic accidents and near hits, particularly, structural collapse, explosions, fires and
damaging releases associated with a loss of containment of energy or dangerous substances
such as chemicals and petroleum products. These engineering and management skills
exceed those required for managing workplace safety as it impacts people, property and the
environment.
PSM is a major issue for the industry, with many organisations looking to adopt a
more holistic and systematic approach to assuring the integrity of their operations. Center for
Chemical Process Safety (CCPS) Guidelines for risk based process safety (RBPS) provides such
a high-level framework: this and other models are being adopted by some organisations (e.g.
PAS 55 and ISO 9001). In addition, PSM may be influenced by legislative requirements (e.g. in
the UK The Offshore Installations (Safety Case) Regulations (OSCR) and The Control of Major
Accident Hazards (COMAH) Regulations).
Whereas many of the larger organisations have been working on these approaches
for a number of years, with significant dedicated resources and varying degrees of success,
others and many of the smaller organisations are looking for consistent guidance as they look
to achieve efficient development and implementation approaches to achieve effective PSM.
One of the first questions asked by many senior executive teams is: how are other people in
similar industries addressing this issue?
The objective of EI High level framework for process safety management (EI PSM
framework) is to provide a simple and systematic approach for organisations large and small
across the energy industry, defining the key things organisations need to get right in order
to assure the integrity of their operations incorporating technical, maintenance, operational,
and human and organisational factors.
EI PSM framework should be applicable to both large and small organisations;
however, the depth of application will vary in order to be applicable to the scope and
complexity of their operations.
EI High level framework for process safety management has been developed by the energy
industry for use by energy industry sectors, capturing and incorporating learnings from people
with practical experience of developing and implementing PSM as part of an integrated
management system (MS).
Two facilitated workshop sessions were held to develop EI PSM framework: an initial
session to explore the need for a framework and what a high-level framework for process
safety management for energy industry sectors in the UK (and EU) should look like. A second
workshop was held to develop EI PSM framework following review of the output of the first
workshop by the PSC and the sanctioning of the framework development as part of the EI's
Technical Work Programme.
The workshop participants were process safety specialists from the various energy
industry sectors who have either implemented a process safety model (whether CCPS RBPS
or another) and had some experience to report, or who were at a lower level of maturity such
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
The first workshop participants supported the need for a PSM framework and identified the
following objectives for it:
−− provide a vision for PSM;
−− define a model for and raise profile of PSM within an organisation;
−− define what needs to be in place to maintain a licence to operate;
−− help to define roles, responsibilities and accountabilities for PSM;
−− easy to understand how to achieve suitable PSM, and
−− provide guidance on how to assure high level of PSM.
A report of this workshop was published as EI Technical workshop proceedings: Initial report
– Framework for high-level process safety management, March 2010.
The second workshop reviewed a draft 'strawman' PSM framework that was
developed ahead of the workshop by a PSC sub-group. The updated draft PSM framework
generated during the second workshop was reviewed by stakeholders in a consultation
exercise, further updated to incorporate pertinent feedback, and approved by the PSC with
this publication (EI PSM framework) as its deliverable.
EI PSM framework is intended to be applicable worldwide, to all sectors of the energy industry
such as petroleum, power, and kindred industries like chemicals. It is designed to address
process safety hazards and to be equally suitable for major processing, production and
operational facilities through to smaller operations, which may not incorporate processing,
such as private power distribution networks, smaller storage facilities and filling stations.
EI PSM framework is not designed to replace existing process safety or health, safety
and environmental management systems (HS&EMSs). It sets out what should be covered
by an existing MS and as such provides a benchmark for good practice. In cases where an
organisation does not have a process safety management system (PSMS) EI PSM framework
provides a design basis for its development. It is also intended to provide a common basis for
the benchmarking of PSMSs.
Where an organisation has a PSMS or an integrated MS incorporating HS&E and PSM
they should carry out a gap assessment versus the expectations of each element in order to
identify any aspects of the system that need to be enhanced.
The gap assessment should be carried out by element with assigned resources, with
appropriate current understanding of the specific subject area being covered. It may be
advantageous to appoint an overall coordinator to assure consistency and delivery of the
overall assessment.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
The initial assessment should look at each expectation and for each one identify:
−− how this is achieved;
−− who is responsible for doing it;
−− who is accountable for ensuring that this is done;
−− any gaps or deficiencies versus the expectations, and
−− what needs to be done to address or close the gap.
When the initial assessment has been completed, the significance of the gaps should be
determined and a prioritised plan should be developed to address the identified issues. In
some cases there may be a significant programme of work required to upgrade the MS to meet
the EI PSM framework expectations. In these cases it should be recognised that this upgrade
work may go on over many months or even years; if this is the case, it may be appropriate to
assign a project manager to apply appropriate project management approaches to see the
work through to completion.
EI PSM framework also provides a basis for periodic audit to assure compliance. The
gap assessment and audit should always be carried out on the basis of evidence rather than
opinion to confirm compliance, in all cases asking to be shown evidence that something is
being carried out in the way that has been described.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
The challenge for the process industry is often clearly set out in three statements by chief
executives as: ensure we don't hurt anyone; ensure we don't harm the environment; and
achieve a certain level of return on capital employed (ROCE).
Typically organisations are very clear about what they need to do to deliver ROCE
– maximise income and optimise operating expenditure – typically they are clear about the
things they need to get right to ensure that these outcomes are as they require. However,
with the safety and environmental targets, quite often things are not so clearly understood.
Generally there are good lagging indicators, telling organisations how many incidents or
injuries they have had; however, very rarely are there comprehensive leading indicators
systematically measuring the factors that determine how likely things are to go wrong and
consequently how likely they are to have an incident or injury in the future. All too often
when asked how they will achieve their safety and environmental targets and how they will
know whether those things are being done, the answers are inconsistent.
EI PSM framework sets out clearly what needs to be done to assure the integrity of
the operation and helps to define what measures should be in place to know whether those
things are being done.
It consists of three levels:
Focus areas These set out the key high level components of the PSM
framework.
Elements Within each of the focus areas are a number of elements which set
out the key aspects of the operation that organisations need to get
right in order to assure their integrity.
Expectations Within each of the elements the expectations define what
organisations need to get right in order to meet the intent of each
element.
There are four focus areas defining the key high level components of EI PSM framework, as
described in 2.1.1‑2.1.4.
This focus area sets out how organisations should define and communicate the level of
performance they are prepared to accept and how they should ensure that they put in place
the necessary resources to achieve the required level of performance.
This focus area sets out how organisations should identify and assess the risks that they need
to manage in order to assure the integrity of their operations, how they identify the necessary
control measures and how they should record and maintain the process safety knowledge
developed from these risk identification and assessment activities.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
This focus area sets out how organisations should implement and manage the control
measures that have been identified during their risk identification and assessment activities.
This focus area sets out how organisations should measure and review their compliance with
the EI PSM framework expectations and how they should ensure that they learn from these
measurements and the findings from investigations.
Within each of the focus areas are a number of elements, 20 in total, which set out the key
aspects of operations that organisations need to get right in order to assure the integrity of the
operations. Each element contains a number of expectations which set out a more detailed
definition of what they need to get right in order to meet the intent of each element.
There are five elements within the process safety leadership focus area that set out how
organisations should define and communicate the level of performance they are prepared to
accept and how they should ensure that they put in place the necessary resources to achieve
the required level of performance:
1. Leadership commitment and responsibility.
2. Identification and compliance with legislation and industry standards.
3. Employee selection, placement and competency, and health assurance.
4. Workforce involvement.
5. Communication with stakeholders.
There are two elements within the risk identification and assessment focus area that set out
what organisations should ensure is done to identify and assess the risks that they need to
manage in order to assure the integrity of their operations, how they should identify the
necessary control measures and how they should record and maintain the process safety
knowledge developed from these risk identification and assessment activities:
6. Hazard identification and risk assessment.
7. Documentation, records and knowledge management.
There are 11 elements within the risk management focus area that set out the key areas of
risk and how organisations should implement and manage the control measures that have
been identified during their risk identification and assessment activities:
8. Operating manuals and procedures.
9. Process and operational status monitoring, and handover.
10. Management of operational interfaces.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
There are two elements within the review and improvement focus area that set out how
organisations should measure and review their compliance with the expectations of EI PSM
framework and how they should ensure that they learn from these measurements and the
findings from investigations:
19. Incident reporting and investigation.
20. Audit, assurance, management review and intervention.
There follow the expectations for each element. Each commences with an overview and
contains a number of expectations which set out a more detailed definition of what
organisations need to get right in order to meet the intent of each element.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
1.1 A documented HS&E and process safety policy is in place and signed by the
chief executive officer (CEO) or the appropriate unit managing director (MD).
These are living systems which are regularly reviewed and updated to reflect
the needs of the organisation.
1.2 HS&E and process safety governance and support arrangements are defined
and implemented at all levels from the board through to the workforce.
1.3 An HS&E and process safety risk MS is in place which meets applicable
legislation, the EI PSM framework expectations and other requirements to
which the organisation subscribes with regard to its HS&E and process safety
activities.
1.4 Management establishes the scope, priority and pace for the HS&E and
process safety risk MS implementation, considering the complexity and risks
involved with their operations and products.
1.6 Sufficient competent resources are in place to cover the defined HS&E and
process safety roles and responsibilities, in order to reduce the likelihood of
overloaded or stressed staff having a detrimental effect which could lead to
an incident.
1.7 Clear HS&E and process safety objectives, performance targets and action
plans are established and performance is regularly evaluated against these.
1.8 Required HS&E and process safety leadership attributes are defined, developed
and integrated into the required competencies for leaders.
1.10 Directors and managers promote an open and trusting environment and
understand how their behaviours impact others.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
1.12 Directors and managers recognise and reward positive HS&E and process
safety behaviours and performance and intervene to correct deviations from
required performance at all levels in the organisation.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
2.2 The operating requirements arising from legislation and industry standards
are defined, documented and communicated to those affected.
2.4 Arrangements for identification and compliance with legislation and industry
standards are understood and followed; understanding of arrangements and
compliance with them is regularly tested.
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
3.1 The required HS&E and process safety competencies and fitness for work and
health monitoring requirements are defined for all roles in the organisation.
These competencies address EI PSM framework expectations.
3.3 Individual and collective experience and knowledge are maintained and are
carefully considered when personnel changes are made.
3.4 Roles and responsibilities are realistically designed to take account of human
capabilities and limitations and other key human and organisational factors.
3.5 Appropriate induction is carried out for personnel taking up a new or revised
position.
3.6 A staffing development and succession plan is in place for all positions with
PSM responsibility.
3.8 Employee competency and fitness for work are regularly assessed against
requirements of their assigned role and responsibilities.
3.9 Employee training and development needs are identified through a systematic
process.
3.10 Systematic and effective training and development programmes ensure that
each person is competent to understand and accept and deliver against the
defined HS&E and process safety responsibilities for their role.
3.13 Arrangements for employee selection, placement and competency, and health
assurance are understood and followed; understanding of arrangements and
compliance with them is regularly tested.
10
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview Achieving the high levels of HS&E and process safety performance requires
the commitment of the whole workforce.
Management must align, involve and empower the whole workforce, in the
identification and management of HS&E and process safety hazards.
4.1 Directors and managers promote an open and trusting environment and
understand how their behaviours impact others.
4.2 Employees and contractors are actively engaged in the improvement of HS&E
and process safety performance and have an understanding of process safety
hazards, their identification and management/control.
11
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
5.2 Organisations ensure and demonstrate that the consultation process with
statutory and non-statutory stakeholders is appropriate and proportionate,
and follows a defined process.
5.3 Appropriate HS&E and process safety information is published in the public
domain to demonstrate the organisation's commitment to continually
improving its performance.
12
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
6.1 A structured process is applied to identify the hazards and ensure that the
risks arising from the organisation's assets and operations are systematically
assessed.
6.2 Risk control measures are identified and implemented, using the hierarchy of
control, to manage the identified risks to a tolerable level.
6.3 The tolerable level of risk is defined for all risks (to human health & safety,
environmental impact, property and financial loss) and is consistently
understood and applied throughout the organisation.
6.7 Risk assessments are carried out by competent personnel with appropriate
independence.
6.8 Risk assessments take into account learnings from incidents from both inside
and outside the organisation.
6.9 Completed risk assessments are reviewed, approved and accepted by specific
levels of management appropriate to the magnitude of the risk and any
decisions are clearly documented.
6.10 All stakeholders are kept informed about the risk assessment process and
results.
13
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
6.12 The implementation of mitigation recommendations for the top HS&E and
process safety risks is reviewed regularly by specified levels of management.
6.13 Risk assessments are updated as changes occur and reviewed and updated
at a defined appropriate frequency.
6.14 Arrangements for hazard identification and risk assessment are understood
and followed; understanding of arrangements and compliance with them is
regularly tested.
14
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview Accurate records and information are essential to identify, assess and manage
HS&E and process safety risk.
Management must ensure that the information required to support safe
operation is identified, available and up to date.
7.1 There are procedures to define, develop and maintain the required
documentation and records necessary to support robust operation and
maintenance of facilities.
7.2 Documentation and records are readily available to those who need to use
them.
7.4 There are procedures to ensure that documentation and records are regularly
reviewed and kept up to date as living systems.
7.6 The required documentation and records include those generated to meet
the requirements of all other EI PSM framework expectations, such as:
−− process design considerations and basis for safe operation;
−− drawings;
−− asset register;
−− equipment records (inspection, testing, maintenance and
modification);
−− equipment specification data;
−− workplace inspection records;
−− work logs;
−− training and competency records;
−− incident investigation reports;
−− occupational health records;
−− operating procedures;
−− environmental authorisations;
−− planning consents;
−− relevant legislation;
−− risk assessments;
−− standards and practices;
−− hazards of materials involved in operations, and
−− product data sheets.
15
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
8.2 Operating manuals are designed to maximise usability and minimise the
likelihood of error and non-compliance.
8.4 Operating manuals and procedures are regularly reviewed and updated;
these reviews involve supervisors and personnel who are required to use
them.
8.5 Arrangements for operating manuals and procedures are understood and
followed; understanding of arrangements and compliance with them is
regularly tested.
16
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
9.1 SOLs are defined for all assets, commensurate with risk.
9.2 There are procedures to ensure that SOLs are regularly reviewed and kept up
to date as living systems.
9.5 Arrangement for SOLs and their significance are understood and monitoring
requirements are followed; understanding of arrangements and compliance
with them is regularly tested.
9.7 Arrangements for process and operational status monitoring, and handover
are understood and followed; understanding of arrangements and compliance
with them is regularly tested.
17
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview Operational interfaces with third parties, who provide or receive services,
utilities, or products may impact the organisation’s operations.
Management must ensure that operational interfaces with third parties are
identified, assessed and appropriately managed.
10.1 Operational interfaces with third parties are identified, documented and risk
assessed.
18
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview HS&E and process safety performance is enhanced by using robust standards
and safe working practices.
Management must ensure that the required standards and safe working
practices, to support project, maintenance and operational activities, are
identified, developed and consistently applied.
11.1 Design, inspection and maintenance standards are defined, which bring
together legislative requirements, industry standards and the organisation's
good practices into a clear set of guidelines to be used when developing
projects, inspection and maintenance plans.
11.2 Safe working practices are defined, which bring together legislative
requirements, industry and the organisation's good practices into a clear
set of guidelines to be used when developing construction, inspection and
maintenance plans and method statements, and for operational activities.
11.4 Approved standards and practices are reviewed, to take into account
changes to legislation, industry standards, industry and the organisation's
good practices and findings from incidents, and are regularly reviewed and
kept up to date as living systems.
11.5 Approved standards and practices are readily available to those who need
them, including contractors.
11.7 Deviation from design standards is permitted only after assessment, review
and approval by specific named competent individuals and after the rationale
for the decision is documented.
11.9 When a new or updated standard or practice is issued, the requirements for
retrospective application are defined.
11.10 Arrangements for standards and practices are understood and followed;
understanding of arrangements and compliance with them is regularly
tested.
19
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
12.6 Temporary changes do not exceed initial authorisation for scope or time
without review and approval.
20
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
12.10 Key stages in the project development lifecycle are reviewed and approved
by specified level of management with due consideration of PSM practices.
12.11 Criteria are established and procedures are in place for conducting and
documenting risk assessments at specific project stages to confirm the
integrity of new assets and existing assets which have been substantially
modified.
12.12 HS&E and process safety impacts of new business development on the local
community are assessed and communicated to relevant authorities and
integrated into the business case.
12.13 The design and construction of new or modified facilities use approved
standards and practices that:
−− meet or exceed applicable regulatory requirements;
−− embody responsible requirements where legislation does not exist,
and
−− encompass robust PSM practices.
12.15 Procedures are in place to identify and manage the HS&E and process safety
risks arising from the mothballing and decommissioning or disposal of assets
including dismantling, demolition and site remediation.
21
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview The commissioning and start-up of new, modified or existing plant and
equipment is a high risk operation.
Management must ensure that there is a systematic process to verify that plant
and equipment is in a safe condition, and that personnel are appropriately
prepared, before start-up or return to normal operation.
13.1 There is a systematic process for checking operational readiness and the
integrity of systems before they are brought into service.
13.3 There are defined criteria for operational readiness reviews and they are
regularly reviewed and updated.
13.5 System checks are carried out and documented by competent personnel.
13.6 There are defined criteria for categorising and handling identified issues and
outstanding work items.
13.7 Completed system checks are reviewed, approved and accepted by specific
levels of management appropriate to the magnitude of the risk.
13.9 Arrangements for operational readiness and process start-up are understood
and followed; understanding of arrangements and compliance with them is
regularly tested.
22
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
14.3 Emergency response plans (ERPs) are documented, accessible and clearly
communicated. The plans based on assessed HS&E and process safety risks
cover:
−− response organisation structure;
−− defined roles and responsibilities;
−− internal and external communication procedures;
−− procedures for accessing and mobilising personnel and equipment;
−− procedures for interfacing with other organisations and external
emergency response organisations;
−− public relations, and
−− recovery and remediation.
14.5 Equipment and facilities needed for emergency response are defined and
readily available and maintained.
14.6 Adequate numbers of competent personnel are available to fulfil the defined
roles in the emergency plans.
14.7 Mutual aid schemes involving relevant third parties and external emergency
services are established and agreed as appropriate.
14.8 A regular programme of drills involving internal and external resources is used
to exercise, develop and improve capabilities for a range of emergencies.
23
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
15.1 Assets are uniquely identified on an asset register which provides up-to-
date asset lists and equipment records, including location and equipment
specification data. The asset register provides a basis for inspection and
maintenance planning.
15.2 The asset inspection and maintenance programmes are risk based and
address and integrate long term asset integrity, HS&E and process safety
compliance assurance.
15.3 There are procedures to ensure that asset inspection and maintenance
programmes are reviewed regularly commensurate with risk, using findings
from the programmes, industry experience and incidents to identify and
address issues and opportunities for improvement, so that they are kept up
to date as living systems.
15.4 Feasible plans and schedules are developed for execution of asset inspection
and maintenance programmes.
15.5 Adequate numbers of competent personnel are available to carry out the
inspection and maintenance programmes.
15.6 There are procedures to ensure that findings and recommendations from the
asset inspection and maintenance programmes are appropriately prioritised
and followed up.
24
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview An essential requirement for HS&E and process safety is that safety critical
equipment and devices (SCDs) are in service and operating correctly.
Management must ensure that safety critical equipment and devices
are identified and appropriately managed, so that they are in service and
functioning correctly.
16.1 SCDs are uniquely identified on an asset register which provides up-to-
date asset lists and equipment records, including location and equipment
specification data. The asset register provides a basis for the planning of SCD
testing, inspection and maintenance.
16.2 SCD testing, inspection and maintenance programmes are in place. There
are defined standards and the programmes are proportionate to the risk
associated with failure of the SCDs.
16.3 There are procedures to ensure that SCD testing, inspection and maintenance
programmes are reviewed regularly commensurate with risk, using findings
from the programme, industry experience and incidents to identify and
address issues and opportunities for improvement, so that they are kept up
to date as living systems.
16.4 Feasible plans and schedules are developed for execution of testing, inspection
and maintenance programmes.
16.5 Adequate numbers of competent personnel are available to carry out the
testing, inspection and maintenance programmes.
16.6 There are procedures to ensure that findings and recommendations from
the SCD testing, inspection and maintenance programmes are appropriately
prioritised and followed up.
25
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview The execution of maintenance and project work activities, if not appropriately
managed, can significantly increase the levels of HS&E and process safety
risk.
Management must ensure that effective work control, permit to work and
task risk management arrangements are in place, and followed, to control
the risks arising from work activities.
17.2 Key stages in the work control arrangements are reviewed and approved by
specified levels of management.
17.4 There are procedures that ensure that HS&E and process safety risks arising
from work tasks are systematically identified and assessed, before work starts
and as circumstances change and where new risks arise during execution of
work.
17.5 Risk control measures are identified and implemented to manage the
identified risks to a tolerable level.
17.7 Completed task risk assessments are reviewed and approved by specified
named competent individuals appropriate to the magnitude of the risk and
any decisions are clearly documented.
17.8 All of the workgroup are made aware of task risk assessments and required
control measures, process and results.
17.10 Arrangements for work control, permit-to-work and task risk management are
understood and followed; understanding of arrangements and compliance
with them is regularly tested.
26
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview Third parties doing work on the organisation's behalf may impact its
operations and its reputation.
Management must ensure that third parties perform in a manner that is
consistent and compatible with the organisation's HS&E and process safety
requirements.
18.1 There is a process to ensure that third party services are evaluated and
selected against criteria that include an assessment of capabilities to perform
work in a robust manner and meet the organisation's HS&E and process
safety performance expectations.
18.2 HS&E and process safety performance evaluation criteria are defined for third
parties. Contractor and supplier compliance with legislation is a minimum
requirement. The evaluation criteria are aligned to the EI PSM framework
expectations.
18.5 Third party performance (in particular against required performance criteria)
is routinely monitored and assessed, feedback is provided, and non-
conformities are corrected.
18.6 Adequate numbers of competent personnel are available to carry out the
required contractor and supplier, selection and management arrangements.
18.7 Arrangements for contractor and supplier, selection and management are
understood and followed; understanding of arrangements and compliance
with them is regularly tested.
27
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
19.2 The reporting of incidents and near hits by all personnel including contractors
and suppliers is obligatory.
19.3 Incidents and near hits are classified and investigated on the basis of actual
and potential outcome.
19.6 Effective arrangements are in place to ensure that incidents or near hits
are appropriately investigated when they involve contractor or supplier
personnel.
19.7 There are processes in place to learn from relevant incidents and near hits,
and good practices in other organisations and sectors.
19.8 Adequate numbers of competent personnel are available to carry out the
required investigation arrangements.
19.10 Where appropriate and recognising legal and security constraints all
stakeholders are kept informed about the findings and recommendations
from investigations.
28
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
19.13 Arrangements for incident reporting and investigation are understood and
followed; understanding of arrangements and compliance with them is
regularly tested.
19.14 Compliance, HS&E and process safety incident statistics and performance
trends are reviewed by specified levels of management.
29
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
Overview Regular review and audit of compliance with the EI PSM framework is vital
to ensure that HS&E and process safety performance continues to meet the
defined targets.
Management must ensure that there is both routine review and independent
audit of compliance with EI PSM framework expectations.
20.2 The organisation's operations are routinely monitored, incorporating the PSM
performance measures, and reviewed, by specified levels of management, at
predetermined frequencies.
20.3 The EI PSM framework expectations are reviewed annually and updated
as necessary to ensure that they continue to meet the needs of the
organisation.
20.4 Audit criteria are defined to provide a consistent basis for audit and a
consistent basis for development of the audit opinion.
20.5 A routine internal (2nd party) audit programme is in place with audits carried
out by personnel from the organisation. The audit assesses compliance with
the EI PSM framework expectations and the effectiveness of the management
review arrangements.
20.6 A routine external (3rd party) audit programme is in place with audits
carried out by personnel independent of the organisation. The external audit
assesses and provides an independent opinion on compliance with the EI
PSM framework expectations and the effectiveness of the management
review arrangements.
20.8 The frequency and scope of the assessments will reflect the complexity of
the operation, the level of risk and previous EI PSM framework compliance
history.
20.9 Audit opinion and findings from the EI PSM framework audits are reviewed
with specified levels of management.
30
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
20.12 Arrangements for audit, assurance, management review and intervention are
understood and followed; understanding of arrangements and compliance
with them is regularly tested.
31
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
ANNEX A
GLOSSARY
A.1 INTRODUCTION
For the purpose of this publication the interpretations in A.2 apply irrespective of the meaning
they may have in other connections.
32
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HIGH LEVEL FRAMEWORK FOR PROCESS SAFETY MANAGEMENT
ANNEX B
REFERENCES
Technical workshop proceedings: Initial report – Framework for high-level process safety
management (March 2010).
33
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Energy Institute This publication has been produced as a result of
61 New Cavendish Street work carried out within the Technical Team of the
London W1G 7AR, UK Energy Institute (EI), funded by the EI’s Technical
Partners. The EI’s Technical Work Programme
t: +44 (0) 20 7467 7100 provides industry with cost effective, value adding
f: +44 (0) 20 7255 1472 knowledge on key current and future issues
e: pubs@energyinst.org affecting those operating in the energy sector,
www.energyinst.org both in the UK and beyond.
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Energy Institute
Process safety survey (EIPSS)
Benchmark your company against
EI High level framework for process safety management
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www.energyinst.org /process-safety-survey
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