Process Safety Fundamentals (IOGP Report 638)

REPORT OCTOBER 638 2020

Acknowledgements This Report was produced by the IOGP Safety Committee.

Front cover photography used with permission courtesy of ©curraheeshutter/iStockphoto and ©lagereek/iStockphoto

About Designed to support those working in front-line operations, maintenance, and on wells teams, the IOGP Process Safety Fundamentals are informed by data and designed to draw attention to situations that are most likely to lead to process safety event fatalities. They are therefore not intended to exhaustively address all process safety risks and hazards in the oil and gas industry, but to be deployed in addition to a company’s underlying systems for process safety management.

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REPORT OCTOBER 638 2020

Revision history

VERSION DATE AMENDMENTS

1.0 October 2020 First release

Contents

Introduction 5

1. The Process Safety Fundamentals 7

2. Implementing the Process Safety Fundamentals 10

3. Supporting information 14 3.1 Guidance cards 14 3.2 Data analysis 25 3.3 Frequently Asked Questions (FAQs) 28 3.4 Definitions 29

Introduction

Data reported by IOGP Members over a period of ten years (2007-2017) shows that 128 people lost their lives in 56 process safety events. In response to this, the IOGP Process Safety Fundamentals (PSFs) have been developed to support companies as they seek to reduce, and ultimately eliminate, fatal and high severity process safety events.

Designed to support those working in front-line operations, maintenance, and on wells teams, the IOGP Process Safety Fundamentals are informed by data and designed to draw attention to situations that are most likely to lead to process safety event fatalities. They are therefore not intended to exhaustively address all process safety risks and hazards in the oil and gas industry, but to be deployed in addition to a company’s underlying systems for process safety management.

Process safety is a disciplined framework for managing the integrity of operating systems and processes that handle hazardous substances. The goal of process safety and asset integrity is to prevent unplanned releases which could result in a major incident.

The content of the PSFs should be familiar to the industry, but presenting these concepts as this Report does offers a tool to enable the front line to get a clearer picture of what process safety means in their day-to-day activities.

IOGP PSFs are not intended to replace company management systems, policies, safe systems of work, safety training programs, operating procedures, or work instructions. In fact, they rely on these frameworks being in place.

PSFs are intended to be used in addition to the IOGP Life Saving Rules (LSRs): complementary but separate. It is not recommended that they are combined into a single list. Whereas the LSRs are primarily focused on personal safety events, albeit with some overlap into process safety, PSFs are specifically targeted at process safety hazards. Although there is some overlap between some LSRs and a PSF (e.g., Energy Isolation) the topic is retained within the PSFs to enable specific treatment of the process safety hazards.

A key success factor in using PSFs is the manner and tone in which they are presented. In this respect, there are some important differences compared to the way some companies deployed their Life-Saving Rules programs, as such programs have often been communicated and managed as mandatory requirements, with compliance strictly enforced.

The PSFs provide focus on supporting the front-line to enable successful process safety performance (see IOGP Report 456 – Process safety - recommended practice on key performance indicators). In some cases, trying to align with a PSF may prove difficult in practice, and employees should be encouraged to openly voice and report these dilemmas without fear of criticism. Bringing these issues into the open enables the company to decide on how to address the concern raised. It is important that front-line workers are given the flexibility to use the PSFs as a supportive tool to help improve process safety performance. The PSFs are not intended to be seen as ‘another set of rules’, and it is strongly advised that they are not associated with disciplinary measures for non-conformance. This approach to launching the PSFs may negate potential benefits that could be gained by the program.

This report presents a core set of ten PSFs. IOGP believes that these core items are relevant to all upstream operations. In some cases, companies may find it beneficial to add to the list based on local process safety challenges. A possible list of additional PSFs, based on existing member company deployments, is provided in Section 2.

Member company experience demonstrates that the PSFs and the Life Saving Rules can be used effectively in harmony with each other.

Table 1: Life-Saving Rules and Process Safety Fundamentals

Life-Saving Rules Process Safety Fundamentals

Focus Strong focus on personal safety with some overlap Solely focused on process safety into process safety

Flexibility Single common industry set recommended by IOGP Core set recommended by IOGP, with flexibility to supplement or exchange a small number based on local process safety challenges

While the IOGP PSFs have been developed based on upstream process safety events, IOGP believes that the PSFS are also applicable to downstream operations. Companies with downstream operations may want to consider including supplementary PSFs to address specific local issues. Fatal wells related process safety events are included in the analysis to develop the IOGP PSFs, so it is believed they are relevant to that area of operation. Companies who wish to apply to well operations may consider including supplementary PSFs to address well operational activities.

IOGP is seeking industry standardisation in recommending a core set of 10 PSFs. It is recognised, however, that some companies may wish to exchange a small number of the core set for others that are more tailored to their company specific operations and process safety challenges or to create standardisation on PSF across different businesses within an integrated company. In doing so, companies are encouraged to align with the core set as far as possible and exercise caution in removing core PSFs given they have been selected based on thorough data analysis.

As part of a continuous improvement cycle, IOGP intends to regularly seek feedback on the following; • Effectiveness of the 10 core PSFs • Other PSFs that have proved useful to IOGP Member companies • Adaptations or supplementary PSFs that have been helpful to include downstream and wells activities

At appropriate intervals, IOGP may update the recommended PSFs based on real-world application feedback from IOGP Member companies.

It is intended that adoption of PSFs: • Provides a focus for process safety at the front-line • Enables process safety concerns to be raised and addressed • Is a step towards industry-wide common language for process safety • Helps companies to eliminate high severity process safety events

This document introduces the Process Safety Fundamentals, the supporting data analysis, and provides implementation guidance. Additional implementation resources will be available at www.iogp.org/psf.

1. The Process Safety Fundamentals

We respect hazards • We improve our understanding of process safety hazards at our location and our roles in controlling them. • We are vigilant about the potential impacts of uncontrolled process safety hazards. • We discuss process safety hazards before starting a task. • We bring forward process safety hazards to be included in activity risk assessments.

We apply procedures • We use operating and maintenance procedures, even if we are familiar with the task. 1 • We discuss the key steps within a critical procedure before starting it. • We pause before key steps and check readiness to progress. 2 • We stop, inform supervision and avoid workarounds if procedures are missing, unclear, unsafe, or cannot be followed. • We take time to become familiar with, and practice, emergency procedures.

We sustain barriers • We discuss the purpose of hardware and human barriers at our location. • We evaluate how our tasks could impact process safety barriers. • We speak up when barriers don’t feel adequate. • We perform our roles in maintaining barrier health and alert supervision to our concerns. • We use an approval process for operations with degraded barriers.

We stay within operating limits • We discuss and use the approved operating limits for our location. • We escalate where we cannot work within operating limits. • We alert supervision if an alarm response action is unclear or the time to respond is inadequate. • We obtain formal approval before changing operating limits. • We confirm that potential for overpressure from temporary pressure sources has been addressed.

We maintain safe isolation • We use isolation plans for the specific task, based on up-to-date information. • We raise isolation concerns before the task starts and challenge when isolation plans cannot be executed. • We check for residual pressure or process material before breaking containment. • We monitor the integrity of isolations regularly and stop to reassess when change could affect an isolation integrity. • We confirm leak-tightness before, during, and after reinstating equipment.

We walk the line • We use up-to-date documentation (e.g., P&IDs1) that accurately reflect installed systems and equipment. • We physically confirm the system is ready for the intended activity (e.g., valve positions, line up of relief devices, etc.). • We alert supervision to identified documentation and readiness issues before operation.

We control ignition sources • We identify, eliminate, or control the full range of potential ignition sources during task risk assessments and during job preparation and execution. • We minimise and challenge ignition sources even in “non-hazardous” areas. • We eliminate ignition sources during breaking containment and start-up and shutdown operations.

We recognise change MOC • We look for and speak up about change. • We discuss changes and involve others to identify the need for management of change (MOC). • We review the MOC process for guidance on what triggers an MOC. • We discuss and seek advice on change that occurs gradually over time.

Piping and Instrumentation Diagrams

We stop if the unexpected occurs • We discuss the work plan and what signals would tell us it is proceeding as expected. • We pause and ask questions when signals and conditions are not as expected. • We stop and alert supervision if the activity is not proceeding as expected.

We watch for weak signals • We proactively look for indicators or signals that suggest future problems. • We speak up about potential issues even if we are not sure they are important. • We persistently explore the causes of changing indicators or unusual situations.

Guidance cards A set of guidance cards to support implementation of the PSFs is available in Section 3.1. These have more detailed descriptions of the activities, definitions, and reference materials, and can support the understanding and implementation of the PSFs. Companies can use these to provide additional help and guidance to the front-line workforce, but they are more specifically intended for the supporting organisation, particularly supervisors and managers.

2. Implementing the Process Safety Fundamentals A key success factor in using PSFs is the manner and tone in which they are rolled out. The following steps are suggested to be followed at site or plant level for the implementation of a PSF program:

Workshop with sponsors of the program Sharing of PSF materials at site or plant level, with the involvement of interested groups and sponsors, can be a useful starting point. A half day workshop can be conducted with the participation of key representatives from HSE and Process Safety, Asset Integrity, Production, Operations, Maintenance, and Well Operations. In addition, the participation of senior management is fundamental to effective implementation of the program, sending a clear message that process safety involves everyone, and is not left to front-line workers alone.

The workshop can have the two main objectives. Firstly, the presentation of the PSF content and program. Secondly, through an interactive approach, to collecting feedback from the front line about how the PSFs can be effectively implemented in their field/plant.

Examples of the questions which could be used to encourage open discussion include: • Why are PSFs important to you and the company? • How can PSFs be effectively implemented in your location? • What needs to be changed to enhance process safety improvement? • How can leadership support the front line in using the PSFs?

One outcome from the engagement workshop can be to formally agree a proposed plan for PSF implementation based on the steps set out below.

Analysis and promotion One or more PSF Promoters or Champions can be identified to coordinate rollout. Based on the local context, companies are strongly encouraged to honour the 10 core PSFs as much as possible, but have the flexibility to integrate additional PSFs (or exchange a small number of the core 10) based on specific local process safety challenges. Companies should be cautious about removing any of the core 10 PSFs as these have been selected using systematic data analysis of fatal events. And adoption of the core set will help drive industry standardisation and language around process safety. If, however, companies do choose to exchange one or more of the core PSFs, this should be supported with a thorough analysis of its internal incident and leading indicator data related to actual or potential high consequence process safety events.

Dedicated coaching sessions on the PSFs are encouraged, to be facilitated by the Promoters/Champions, with the purpose of further enabling front-line workers to understand the scope and objectives of the PSF program. The sessions can also provide

clarification on the meaning of each PSF and promote discussion of potential front-line dilemmas. Data analysis on which the selection of the PSFs is based can be shared and opinions and suggestions from the front line can be collected.

The amount of time needed to complete the Analysis and Promotion phase can be variable depending on a variety of factors, such as the size of the organisation involved (one site vs. multiple sites, small or simple asset vs. large or complex asset, etc.), the type of agreements in place and number of involved parties (Production Sharing Agreements, Joint Ventures, etc.). One option could be to initially select a minimum set of PSFs to be promoted during a pilot phase over a one-year program, allowing a better estimate of the required effort in terms of budget and resources allocation for a full-scale deployment over the following years.

Rollout The rollout phase of the PSF program should be viewed as an ongoing engagement of the whole organisation. Each organisation can adopt the most suitable tools and approaches, including:

Awareness campaigns: ongoing sharing of the PSFs with the front-line workforce, referencing real events that have occurred at site level, but also taking into account lessons learned and other available material from the industry.

Videos: meaningful videos can result in greater attention to and retention of information. They increase audience understanding, trigger emotions and encourage participant questions. A short video could be developed for each of the PSFs, to explain its importance and the roles played by employees in preventing undesired process safety events.

Posters: posters can be a powerful communication tool, providing strong relevant images that can be displayed at strategic positions. A well-chosen image can often convey a meaning more powerfully than words alone.

Booklets/brochures: A pocket-sized booklet covering the PSFs can be a helpful resource to maintain awareness of PSFs and be used to prompt process safety discussion, for example during toolbox talks, or during operational site visits by managers and supervisors.

Recognition and interventions: Site hazard observation cards contain the PSFs, and use of the PSFs is encouraged by company programmes that recognise and award workers for utilising the PSFs. PSFs may also be included in the pre-job Toolbox Talks materials, helping to increase understanding of the required controls to be applied before starting work.

Site visits and inspection program: dedicated site visits should be conducted by supervisors and managers to support implementation of the PSFs; dilemmas raised by front-line workers can then be addressed to facilitate continual improvement in process safety performance.

Integration into contractual agreements: the PSFs adopted inside the Company can be referenced in tender documentation, not necessarily as a standalone document, but in a suitable way that ensures Contractors working on the Company’s sites are fully aware that PSFs are part of Company policies/procedures.

Integration into existing systems and processes: implementation of PSFs can be made more efficient and sustainable by integration of the associated activities and communication into existing systems and processes (e.g., shift routines, maintenance planning, permit to work activities).

Monitoring and follow-up Some time may be needed to measure the outcomes of implementing PSFs in a company.

As fatal process safety events (PSEs) are relatively rare in any one company, it may be more