The Baker Panel Report - ABSA

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3. Understanding and recognition of change at the levelwhere changes occur4. MOCs are written when changes are made that are notreplacement in kind5. Changes are implemented following appropriateauthorization6. Follow up on actionsx. Training – at all levels1. Operator training and certification2. Refresher training3. Management understanding of the process, qualificationto make critical process safety decisionsxi. Emergency response measures for coping with on-site and offsiteaccident impactsxii. Audits and reviews1. Frequency and methodology for process safety audits2. Expertise and background of auditors3. Criteria for composition of audit teams (e.g. BP -Internal to Plant, BP - external to plant, BP - Corporate,3 rd party, etc.)4. Status of response to recommendations from audits5. Description and findings of BP corporate, 3 rd party, orregulatory agency auditsxiii. Status and timeliness of completion of process safetyrecommendations from any source – PHA studies, incidentinvestigations, management of change reviews, capital projectprocess safety reviews, etc.1. Quality and effectiveness of the system for trackingrecommendations and ensuring their timely resolution2. Documentation and communication of reasons for nottaking a specific recommendation, includingexplanation of why it is not appropriate and/ordescription of alternative actions takenxiv. Other systems important to process safety, including1. Control of block valves under relief devices2. SIS bypass management38
Appendix B – PSM Review Team Leader BiosJ. S. (Steve) Arendt (sarendt@absconsulting.com)Mr. Arendt is a Vice President of ABSG Consulting Inc. – Organizational PerformanceAssurance Center. He was formerly a co-founder and President of JBF Associates, Inc.He has over 25 years experience in chemical process safety and risk management and hasperformed hundreds of safety analyses, risk assessments, audits, and accidentinvestigations on a variety of oil, gas, chemical, and related industry processes.Mr. Arendt is a widely published author, having over 50 articles, guides, and books to hiscredit on PSM and risk management topics, including: A Compliance Guide for EPA’s Risk Management Program Rule, API, CMA,1997 Manager's Guide to Quantitative Risk Assessment, CMA, 1989 Resource Guide to the Process Safety Code of Management Practices, CMA, 1990 Guidelines for Hazard Evaluation Procedures, Second Edition, CCPS, 1992 A Manager's Guide to Implementing and Improving MOC Systems, CMA, 1993 Risk Communication Guide, Chemical Educational Foundation, 1999He has recently conducted several industry surveys on PSM "best practices," obtaininginformation from over 70 companies, which was used in an industry "PSM best practicesworkshop" sponsored by API. Mr. Arendt’s current activities include managing the APIUniversity Global Process Safety and Risk Management Training Initiative. Mr. Arendtis a member of several safety-related professional societies and is very active with theAmerican Institute of Chemical Engineers and the Center for Chemical Process Safety –for which he is co-authoring two guidelines entitled: Guidelines for Risk Based Process Safety Guidelines for Management of ChangeSince 1989, Mr. Arendt has worked with several industry groups to develop technicalpositions dealing with OSHA's process safety management regulation (29 CFR 1910.119)and EPA's risk management program rule (40 CFR Part 68). He has been an activeparticipant in these rulemakings, providing testimony at the public hearing for bothregulations. Mr. Arendt has served as a moderator for numerous industry workshops onthe OSHA PSM and EPA RMP regulations, and is a frequent speaker at conferencesinvolving chemical accident prevention and process safety management activities.Mr. Arendt was awarded the 2006 Merit Award from the Mary Kay O’Connor ProcessSafety Center, recognizing significant contributions to the advancement of education,research, and service activities related to process safety concepts and/or technologies.Mr. Arendt received a Master of Engineering degree from the University of Tennessee in1977, and is a registered Professional Engineer in the state of Tennessee.39
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JANUARY 2007THE REPORT OFTHE BP U.S
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PANEL STATEMENTProcess safety accid
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RETIRED ADMIRAL FRANK L. “SKIP”
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DR. NANCY LEVESON is a Professor of
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DR. DOUGLAS A. WIEGMANN, Ph.D. is t
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• Dennis C. Hendershot, Principal
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The Panel’s FindingsThe Panel foc
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Process safety cultures at BP’s U
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Process safety audits. The Panel fo
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RECOMMENDATION #5 - CLEARLY DEFINED
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TABLE OF CONTENTSI. The Panel’s R
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A. Scope and MethodologyI. THE PANE
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interview, and at least one attorne
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PROCESS SAFETY REVIEWSThe CSB’s u
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BP requested that the Panel use the
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would be positive from a process sa
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more of the Panel’s recommendatio
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management systems. The charter doe
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observed at BP are likely not limit
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II. PRECIPITATING EVENTS FOR THE PA
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As the Mogford Report explains, the
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III. OVERVIEW OF PROCESS SAFETY, PE
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elated to personal safety performan
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ENDNOTES FOR SECTION III1 29 C.F.R.
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IV. OVERVIEW OF BP’S ORGANIZATION
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Although lower levels of supervisor
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segment includes the manufacturing
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Browne, who has a diverse backgroun
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BP provides no specific training fo
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The new Safety and Operations funct
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The primary purposes of this new or
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maintain a culture in which reliabi
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TEXAS CITYBP acquired the Texas Cit
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25 BP evaluates (1) “Level 5 Lead
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(7) pre-start-up safety review,(8)
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Assessment, assurance, and improvem
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BP control of work standardBP issue
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BP PROCESS AND PERSONAL SAFETY BOOK
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ENDNOTES FOR SECTION V1 BP addresse
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A. Corporate Safety CultureVI. FIND
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Process safety as a core value in B
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contractors and employees in the pr
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A fourth and similar survey item ad
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The Panel recognizes that Browne is
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BP management’s focus on personal
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milestones to guide the efforts of
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Refinery plant manager turnoverUnde
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EMPLOYEE EMPOWERMENTThe Panel belie
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Survey responses substantiate that
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As discussed later in this section,
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U.S. refinery staff and capabilityB
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In 2002, BP commissioned a report b
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The process safety culture survey r
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Worker fatigue and overtimeThe Pane
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As demonstrated below, process safe
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decision to reduce spending on insp
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environmental, and operational goal
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THE PROCESS SAFETY CULTURE AT EACH
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Finally, the Panel’s own observat
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Survey responses from Cherry Point
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process safety culture at the refin
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Table 22‘‘I can report hazardou
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The Panel found other issues that c
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Table 27“In my opinion, process s
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(2) accountabilities for protection
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All levels of management reported t
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Table 32“The training that I have
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Hourly workers interviewed largely
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Table 34“Refinery management puts
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Finding:Each of BP’s five U.S. re
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Table 36“Workers sometimes work a
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Finally, relatively high percentage
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Also indicative of perceived noncom
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ENDNOTES FOR SECTION VI.A1 Meredith
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51 Ibid, p. ii.52 Ibid, p. 153.53 I
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Finally, because the nature and sco
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At the Carson, Cherry Point, and To
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The 2003 audit report for BP South
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COMPLIANCE WITH INTERNAL PROCESS SA
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Table 40Percentages of Disagree/Ten
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Prioritization of inspections and m
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Whiting (2006) Not all of the alarm
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Point have implemented the standard
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the facility siting risk to personn
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The ANSI Z490.1-2001 standard provi
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key positions, BP should assess and
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interviews at some of the refinerie
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Information relating to BP’s Texa
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Computer-based training. Based upon
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TRANSLATING CORPORATE EXPECTATIONS
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In early 2005, prior to the Texas C
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The table below contains the substa
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Interviews with various members of
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BP’S PROCESS SAFETY MANAGEMENT SY
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usiness units, to prioritize implem
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Turnaround deferral procedure (Cars
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on December 4, 2006. In that recomm
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C. Performance Evaluation, Correcti
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valves, and other safety-related eq
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Tracking of process safety indicato
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Table 57Number of Overdue Inspectio
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Although the Panel recognizes that
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Previous concerns about measuring p
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BP’s efforts to develop process s
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BP’S INVESTIGATION AND ROOT CAUSE
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The Panel also identified some defi
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Similarly, although mixed responses
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Other external reviews of BP’s pr
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Table 62Number of Reported Near Mis
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Table 64Percentage of Agree/Tend to
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BP’S PROCESS SAFETY AUDIT SYSTEM>
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compliance or BP policy (Priority 1
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Interviews with members of the Safe
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Refining line management above the
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The audit team found similar proble
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The issues that the Panel’s techn
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USING RESULTS OF INCIDENT INVESTIGA
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Issue Grangemouth Texas CitySafety
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CORPORATE OVERSIGHTAn effective pro
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Selected excerpts from the EEAC rep
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Group- and refining-level process s
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Knowledge of performance management
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Each member of the board needs to a
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ENDNOTES FOR SECTION VI.C.1 America
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43 Health & Safety Executive, Devel
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82 When conducting reviews, BP desi
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138 Health & Safety Executive, Majo
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cultures, process safety management
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(i) implement a policy regarding ar
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(f) educate and provide training to
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workers are educated, encouraged, a
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RECOMMENDATION #6—SUPPORT FOR LIN
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(3) “periodically update”—The
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RECOMMENDATION #9—BOARD MONITORIN
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ANNEX I—PROCESS INCIDENT INDEX EX
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a fatality that results from a mech
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III. Structure and Operations The C
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11. On August 10, 2005, the Texas C
Page 291: APPENDIX CBP U.S. REFINING ORGANIZA
Page 295 and 296: APPENDIX DWHITING RUPTURE DISK: A C
Page 297 and 298: B. INADEQUATE REVIEW AGAINST TECHNI
Page 299: management review or monitoring pro
Page 303 and 304: 214-06GEMS 1544316Review of Process
Page 305 and 306: Executive SummaryOn March 23, 2005,
Page 307 and 308: Based upon its work, the PSM Review
Page 309 and 310: Table of ContentsSectionPageExecuti
Page 311 and 312: 1. IntroductionOn March 23, 2005, t
Page 313 and 314: Following these general sampling pr
Page 315 and 316: Review of documentsWalkaround inspe
Page 317 and 318: 3. Discussion of FindingsBased upon
Page 319 and 320: 3.1 Rupture Disks Under Relief Valv
Page 321 and 322: 3.2 Equipment Deficiencies - Known
Page 323 and 324: Once a site specifies the frequenci
Page 325 and 326: System Finding 3 - Equipment inspec
Page 327 and 328: accepted good engineering practice
Page 329 and 330: Not implementing action items or ta
Page 331 and 332: 3.9 Compliance Audit Findings - Rep
Page 333 and 334: 3.11 Near-miss Investigation - Inad
Page 335 and 336: from water. However, the PHA report
Page 337 and 338: Appendix A - Scope of Work for BP I
Page 339: v. Safety instrumented system desig
Page 343 and 344: Jack McCavitMr. McCavit is Presiden
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Page 348 and 349: Operations network.performance.Refi
Page 350 and 351: C. Performance Evaluation, Correcti
Page 353: APPENDIX GPROCESS SAFETYCULTURE SUR
Page 356 and 357: INTRODUCTIONWelcome to the BP U.S.
Page 358 and 359: I. ABOUT MEIn this section you are
Page 360 and 361: SURVEY TERM DEFINITIONSPlease read
Page 362 and 363: Safety Values / Commitment to Proce
Page 364 and 365: Procedures and EquipmentNote: For e
Page 366 and 367: Process Safety TrainingNote: For ea
Page 368 and 369: PLEASE DO NOT WRITE ON THIS PAGE.14
Page 370 and 371: TermHSSEIncidentISAIsomerization (I
Page 373: ACKNOWLEDGEMENTSMembers of the BP U
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The Baker Panel Report - ABSA

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