The Baker Panel Report - ABSA

BP process safety/integrity management standardIn May 2001, BP issued a process safety/integrity management (PS/IM) standard directed toward process safety/integrity management at BPfacilities. Intended to support the delivery of the HSE expectations in gHSEr, BP promulgated this standard partly in response to three majorprocess incidents that occurred at the BP Grangemouth Petrochemical Complex in Scotland during May through June 2000.The PS/IM standard sought to “help prevent the occurrence of, or minimize the consequences of, catastrophic releases of hazardous materialsand to assure facilities are designed, constructed, operated[,] and maintained in a safe fashion using appropriate codes and standards.” Itestablished requirements in the following areas related to process safety and integrity management: hazard evaluation, management ofchange, mechanical integrity, protective systems, competent personnel, incident investigation, emergency response, and performancemanagement and assurance. BP viewed the eight requirements comprising the PS/IM standard as having their basis in the gHSEr expectations,and applicable gHSEr expectations were linked to each of the eight requirements. A key aspect of the PS/IM standard is the requirement that“[a]ll facilities must systematically identify hazards within its boundary arising from normal and abnormal operations and shall eliminate/control/mitigate the hazards such that residual risks are as low as is reasonably practicable.” 30 The new integrity management standard,described below, has superseded the PS/IM standard.> BP integrity management standardBP designed the integrity management standard to ensure that equipment used in BP operations is fit for service, thereby avoiding loss ofcontainment incidents. In promulgating this standard, BP observed that it was derived from, and intended to improve upon, the 2001 PS/IMstandard. The integrity management standard defines a formal approach to management of integrity at BP operations during all phases ofequipment life: from design and construction, through operation and maintenance, to decommissioning. BP’s U.S. refineries have begun toimplement the integrity management standard, with full implementation required by December 31, 2008. 31 BP has recently developed an auditprotocol for assessing compliance with the integrity management standard.The integrity management standard has ten elements: (1) accountabilities, (2) competence, (3) hazard evaluation and risk management,(4) facilities and process integrity, (5) protective systems, (6) practices and procedures, (7) management of change, (8) emergency response,(9) incident investigation and learning, and (10) performance management and learning. According to BP, the integrity management standardhas incorporated all elements of the superseded PS/IM standard. However, the Panel notes that the integrity management standard’s hazardevaluation and risk management element does not contain the PS/IM standard’s requirement that identified risks be mitigated “as low asreasonably practicable.” Instead, the new integrity management standard contains a more general requirement that BP operations “identifyand mitigate” integrity management hazards and risks, including development of a hazard and risk register for each BP operation with links tothe measures, systems, processes, and procedures in place to manage or mitigate the risks.The integrity management standard requires all BP operations to conduct an assessment for quantifying and ranking major accident risks. Thismajor accident risk methodology is described in BP Group Engineering Technical Practice GP 48-50, Guidance on Practice for Major AccidentRisk Process, discussed below. To ensure that the assessments are done consistently from one refinery to the next, BP’s Head of Major Hazardsand Fire established dedicated teams to conduct major accident risk assessments of BP refineries. In addition to major accident riskassessments, the integrity management standard also requires each site to develop formal procedures for identifying and managing integritymanagement hazards associated with both normal and abnormal operations.BP’s HSSE Management Framework and Process Safety Related Standards C 51