The Baker Panel Report - ABSA

In early 2005, prior to the Texas City incident, BP also initiated a program known as the maintenance accelerator program (MAP). BP’sU.S. refineries are currently in the process of implementing this new program. The MAP was designed primarily to improve availability throughmaintenance principles and practices, and the stated vision of the MAP is to optimize availability, to maximize overall commercial delivery, andto create a “step change in asset availability.” The MAP incorporates process safety into its minimum requirements and includes anexpectation that process safety requirements are met.BP’s MAR program. Of the programs and practices listed above that address process risk, only BP’s major accident risk (MAR) programappears to provide measurable criteria for the management and ongoing reduction of process risk. BP’s various other programs and standards,including the process safety minimum expectations or PSMEs, do not provide such measurable criteria. For example, the PSMEs establishminimum expectations for various hazardous substances and processes, including hydrofluoric alkylation. BP’s U.S. refineries monitorcompliance with those minimum expectations through gap analyses conducted periodically. When gaps are identified, a plan is developed toeliminate the gap. However, the PSMEs do not contemplate or provide for continuous risk reduction beyond the minimum expectations. The newintegrity management standard requires that each U.S. refinery identify and mitigate integrity management hazards and risks and that BPRefining identify in its annual engineering plan the top five integrity management risks. Yet, the standard provides no further measurablecriteria or guidance for process risk management or reduction except to require all BP operations with the potential for a major incident toassess their risks using the MAR process as described below. Other than the MAR process, BP’s standards and practices neither define norprovide guidance to the U.S. refineries on the appropriate role of qualitative or quantitative risk management criteria.Inherent limitations of BP’s MAR program. BP’s MAR program attempts to identify potential incidents that could result in multiple fatalitiesand/or severe damage to the environment or impact on the reputation of the BP Group. The MAR assessment focuses on incidents that couldhave such a large consequence that they could threaten the sustainability or existence of the entire BP Group. BP’s refining process safety/integrity management audit protocol and its new 2006 integrity management standard mandate the MAR program for assessment of majoraccident risks.The MAR program has significant limitations and is not intended to be the sole hazard evaluation and risk management tool available to BPrefinery management. Other hazard management tools available to manage risks include management of change procedures, hazardidentification, hazard and operability studies, quantified risk assessments, and internal standards or guidance, such as BP’s engineeringtechnical practices.As described in the Mogford Report, Texas City conducted a MAR assessment for the Texas City site in March and April 2003. While theassessment addressed the top 80 risks of the site, it did not recognize or include any risks from blowdown drums or the ISOM unit that wasinvolved in the Texas City accident. 64 The Mogford Report notes that a site environmental assessment at Texas City identified the blowdowndrums during shutdowns and relief valve releases as the second highest ranked item. The Mogford Report also notes that “it is apparent thatthe blowdown drums did not receive the same focus for safety risks as they did for environmental risk.” 65The MAR engineering technical practice and continuous risk reduction. The ETP that prescribes the MAR process states that all BPoperations should have a process in place to demonstrate continuous risk reduction. This ETP further provides:Because of regional cultural differences (e.g. over the applicability of cost benefit approaches) there is no Groupmandated approach. Segments, with input from the Regions, should decide how this can best be achieved and whatmetrics should be adopted.The ETP then provides two examples of possible ways to establish risk reduction. First, the ETP provides as an example the establishment oftarget timescales to progressively reduce risks as shown by a plot of possible cumulative frequency of events resulting in some number offatalities. For example, the target timescale might be to reduce total risks to be at least some factor below the Group reporting line in someProcess Safety Management Systems C 168