The Baker Panel Report - ABSA

The Mogford ReportThe Mogford Report found that no plans existed at Texas City to systematically reduce safety risks at the refinery and that no individual or groupseemed to have the accountability for driving process risk reduction across the site. For example, the report found that no plans existedregarding the ultimate replacement/reconfiguration of the blowdown stacks. The report also specifically found that site management did notappear to be focused on understanding and reducing the highest risks. 66> BP’S use of compliance auditsBP appears to have used to some extent infrequent process safety management audits, which are required to be conducted every three years, tomanage toward continuous process risk reduction rather than to have implemented a management system that embodies continuous riskreduction criteria and methodologies. For example, the cover letter transmitting the report for the 2005 Carson process safety managementaudit states that[t]he review reflects the requirements of the Process Safety Community of Practice [Process Safety Integrity Management]compliance protocol that provides the bridge from the high-level gHSEr and [Process Safety Integrity Managment]expectations to actual plant [Process Safety Management] and [Risk Management Program] activities.Priority 2 actions reflect an opportunity and resolution is important to the continuous improvement of the Carson [ProcessSafety Integrity Management] and [Risk Management Program] processes.Letters accompanying the process safety management audits for other refineries during the last few years have been substantially similar tothe 2005 Carson letter.gHSEr audit findings support this apparent misplaced use of compliance audits and reviews, rather than management systems. For example,the summary of findings relating to 2003 gHSEr audits found that “[t]here is a need for greater clarity on HSE monitoring (as part of an HSEmanagement system), specifically ...anentity’s responsibility to monitor and audit its own processes to ensure that they are robust andoperating as intended (rather than rely on external audits).”> Conclusion on continuous risk reductionEven though the MAR engineering technical practice, together with examples, illustrates techniques by which a program of continuous processrisk reduction might be managed, the Panel’s examination found no indication that Refining and Marketing generally, or BP’s U.S. refineriesspecifically, have adopted or implemented any such risk reduction tools. Furthermore, the Panel’s examination indicated that BP has nottranslated its aspirational, high-level corporate goals and expectations as provided in gHSEr and the 2001 process safety/integritymanagement Group standard into specific, operational criteria for managing process risk at the U.S. refineries. While the 2001 standard didexpress the “as low as reasonably practicable” standard for risk reduction, some senior leaders at the U.S. refineries appear generally not tohave been aware of that risk reduction standard—and BP corporate-level management appears to have taken no meaningful steps prior to theTexas City incident to enforce that standard or to translate it into operational reality at its U.S. refineries.Similarly, the Panel’s examination did not detect any indication that BP defined for its U.S. refineries the appropriate role of qualitative orquantitative risk-management criteria. The new Group integrity management standard appears to maintain the status quo regardingcontinuous risk reduction by directing that such risk reduction process be managed at the segment level and continuing the requirement thatglobal business units, such as Refining, identify their top five integrity management risks.Process Safety Management Systems C 171