The Baker Panel Report - ABSA

Assessing performance of the process safety management systemgHSEr framework. On paper, BP recognizes the importance of ensuring that its safety management system functions as intended. Element13 of gHSEr, Assessment, Assurance and Improvement, provides that BP “will periodically assess the implementation of and compliance withthese Expectations to assure ourselves and stakeholders that management processes are in place and working effectively.” 142 Subelement13.10 establishes the expectation that “[a] process is in place whereby assurance is regularly provided to the Group Chief Executivedemonstrating effective implementation of the BP HSE Policy and Expectations.” 143System for assuring performance. BP’s system for assuring process safety performance utilizes a bottom-up reporting system that originates witheach business unit, such as a refinery. The exact reporting hierarchy for BP’s U.S. refineries has changed as BP’s organizational structure for Refininghas evolved. 144 Presently, each U.S. refinery manager prepares an annual report regarding HSSE assurance that is submitted to the Group Vice-President, Refining and refining-level support staff. Refining then aggregates information considered to be relevant and submits an annual HSSEassurance report for worldwide refining operations to the Chief Executive, Refining and Marketing and to segment-level support staff. By the time theHSSE performance is aggregated at this level, refinery-specific information is no longer presented separately. Next, the Refining and Marketingsegment does the same with relevant HSSE information for the entire segment and submits an annual HSSE assurance report to the Group ChiefExecutive and Group-level HSSE staff (currently, the Safety and Operations function). A report summarizing the overall Group HSSE performance is thenprepared and submitted to the EEAC.Reports to the EEAC. The reports to the EEAC for 1999 through 2005 indicate that BP management was focusing on process safety matters,including plant and operational integrity issues. The reports discuss major incidents at different facilities, including Grangemouth (2000report year); Texas City (2001 report year); Grangemouth, Kwinana, Australia, and Nerefco, the Netherlands refineries (2002 report year); andTexas City and El Morgan, Egypt (2003 report year). The reports identify HSSE risks that various levels of the organization confronted anddescribe management actions proposed to address and mitigate those risks, including development of a Group HSSE standard for process safety (2000); development of standards for process safety and for addressing major incident risk and development of “8 Golden Rules” (2001); Group HSSE monitoring of performance by BP segments in completing high priority action items, sharing and embedding of lessonslearned, overdue planned inspections, and number of loss of containment incidents (2002); continued implementation of the Group process safety/integrity management standard and development of a “strengthened”process safety/integrity management functional standard intended to refocus resources for managing process safety (2003); launch of a global project to enhance HSSE compliance management programs worldwide and development of a U.S. HSSEcompliance framework (2004); and introduction of a more rigorous and comprehensive management system to integrate operating excellence, integrity management,and engineering technical practices with health, safety, and environmental best practices and standards (2005).Performance Evaluation, Corrective Action, and Corporate Oversight C 226