The Baker Panel Report - ABSA

Interviews with members of the Safety and Operations function indicate that the auditing group’s role will consist of two steps. First, the groupproposes to audit the completeness of the management systems being used at the sites and whether the sites have the right tools to managethe facilities and evaluate compliance. Second, the group proposes to conduct deep sampling to ensure that what is in the system is what isbeing done. The auditing process will be used both to help build management controls and processes and to verify that they are being followed.BP has advised that the audits will be less system-based and more compliance-based, meaning that the audits will focus less on whetherpaperwork is in place and more on whether procedures are being followed.BP proposes that the entire audit process will take approximately 60 days, including the audit team leader’s first visit to the site, developmentof the audit focus, and development of the audit protocol. The audit team contemplates three to four days of pre-work, followed by ten days ofactual audit fieldwork.BP contemplates that in these audits, the audit leaders and the refinery managers will agree on a time frame for resolving audit findings andfor taking corrective action, which will be shared with senior refining line management above the refinery level and with segment leadership.BP also has plans for independent verification. Safety and Operations proposes to track and verify closure of action items resulting from itsaudits. If action items are not closed in a timely manner, they will be brought to the attention of senior refining line management above therefinery level, the Chief Executive for the Refining and Marketing segment, as well as the Group Chief Executive.BP has also indicated that its internal audit group will review the Safety and Operations audit process once a year. As part of this effort, BPInternal Audit will review the level of rigor in the auditing process as well as the locations Safety and Operations is auditing.In mid-2006, BP identified improvement of audit finding closure as an element of six new expectations that apply to operational leadership. 83Under this new element, sites must (1) focus on closure of agreed action items from audits, regulatory inspections, and major accidentinvestigations; (2) address all outstanding action item backlogs; (3) provide assurance that closed action items have been resolved in arigorous way that would be confirmed through external scrutiny; and (4) develop reasonable timelines for addressing all new action items.The Panel recognizes that BP is in the process of making significant changes to its audit program after the Texas City incident. If BP effectivelyimplements and then sustains these changes, the Panel believes that they will greatly enhance BP’s process safety audit system.Finding:BP has not implemented an effective process safety audit system for its five U.S. refineries.Performance Evaluation, Corrective Action, and Corporate Oversight C 213