AI-PS Element Guide

Element 15: Conduct of Operations

Doc. Reference: GU-XXX-15

Version: Issue 1.0
Date: 10 August 2011
Doc. Owner: Head of Technical Safety Engineering (MSE4)
Element Owner: PTW System Coordinator (UOP7)
AI-PS Element Background There are 20 elements in total within the PDO AI-PS Management
System as follows:
AI-PS in PDO
Elements list:
Assuring the safety of our people, our assets, the environment and
the companys reputation is a core value of PDO and providing Element 1: Process Safety Culture
assurance that we are managing our major process safety risks is a Element 2: Compliance with Standards
critical aspect of our corporate governance. Asset Integrity Process Element 3: Corporate Process Safety Competency
Safety (AI-PS) describes the way we manage our assets so that the
process risk is As Low As Reasonably Practicable (ALARP). Element 4: Workplace Involvement
Element 5: Stakeholder Outreach
What it is Element 6: Process Knowledge Management
Element 7: HEMP
Asset Integrity Process Safety (AI-PS) is the means of ensuring that
the people, systems, processes and resources, which deliver Element 8: Plant Operating Manuals
integrity, are in place, in use and fit for purpose throughout the Element 9: PTW
whole lifecycle of the asset. The aim is to be able to confidently Element 10: Technical Integrity
state that our assets are safe and we know it. Element 11: Contractor Management
Element 12: Training and Performance Assurance
Asset Integrity Process Safety Management is a complex area of
expertise covering a wide range of components, all of which are Element 13: Management of Change
essential to ensuring systems, processes and equipment perform as Element 14: Readiness for Start Up
required. There are a number of Elements which make up the Asset Element 15: Conduct of Operations
Integrity Process Safety management system. Element 16: Emergency Management
Structure of AI-PS Assurance in PDO Element 17: Incident Management
Element 18: Measurements and Metrics
PDO has a three-tiered approach to AI-PS assurance: Element 19: Audit and Verification of Level 2 Process
Level 1: Includes audits conducted on behalf of PDO's Internal Audit Element 20: Management Review and Continuous Improvement
Committee (IAC) as part of the Integrated Audit Plan. This includes
independent audits carried out by external bodies, such as Shell. Element 15: Conduct of Operations
Level 2: Includes audits carried out on behalf of Asset Managers as
Background to Element
part of their own Asset level assurance processes.
Level 3: Includes task verification and assurance activities that To ensure safety, it is necessary that all personnel be fully aware of
supplement the formal audit process. the demands of safety, embrace and respond effectively to these
demands, and continuously seek better ways to maintain and
improve safety. This recognition will help to ensure that operating
policies that result in safe operations are implemented and that
adequate margins of safety are always maintained. The structure of
the organisation, the management standards and administrative
controls should be such that it is ensured to a high degree that
policies and decisions for safety are implemented, that safety is
continuously improved and that a strong safety culture is
developed, thoroughly implemented, promoted and embraced.
Regardless of the extent of automation of a plant, the final decisions
on operation and the resulting ultimate responsibilities for the
operation and maintenance rest with the respective personnel of
these departments. All personnel have a direct impact on plant
operations and the associated systems and components.
Aims and Objectives of Element
To provide recommendations to ensure that plant operations are
conducted in a safe, effective, thorough and professional manner, in
accordance with established PDO requirements and, where
possible, best international practices.
Scope of Element
The scope of this element applies to all PDO operational sites to
ensure that all operations are carried out in a consistent and
appropriate manner.
Requirements of Element
To establish and maintain an effective safety culture throughout the
organisation by engaging an enthusiastic, competent and
committed workforce.
AI-PS Element Guide Implementation
Aims and Objectives of AI-PS Element Guide
The aim of this AI-PS Element Guide is to provide background to AI-
PS and a structured and consistent approach to carrying out Level 2
Self Assessments and Level 3 Verification for all AI-PS Elements
within PDO.
The intended audience for the guide are the members of the
AIPSALT although this can be used as a basis for training and
awareness for all staff at the asset.
Responsibilities and Accountabilities for AI-PS Element Guide
Implementation
The Operations Manager is accountable for the Level 2 Assurance
process at the asset.
Completion of the Level 2 Self Assessment and Level 3 Verification
Checklists, as provided in this element guide, is the responsibility of
the Element Champions and AIPSALT. The Delivery Team Leader
(DTL) is accountable for the AIPSALT.
AI-PS Assurance Leadership Team (AIPSALT)
The AIPSALT is comprised of the asset DTL and Process Safety
Element Champions (PSEC).
The DTL and PSEC roles include: reporting the status of the Level 3
Verification activities for the relevant Element at the AIPSALT
meeting; maintaining Key Performance Indicators (KPIs) for the
Element; monitoring the effectiveness of the Level 3 Verification
activities in assuring AI-PS, and recommending changes to improve
effectiveness and efficiency as appropriate; monitoring the progress
of corrective actions and improvement plans associated with that
Element; and leading Level 2 Self-Assessment of compliance with
the requirements of that Element.
Level 2 Assurance
Level 2 Self Assessment and Audit
Level 2 assurance is provided by a series of AI-PS audits carried out
on behalf of Asset Directors and Operations Managers as part of
their own Directorate-Level assurance processes.
Level 2 Audits (and Level 2 Self Assessments) are conducted at each
Directorate using standard protocols and templates described in
this series of AI-PS Element Guides.
The Level 2 Self Assessment Checklist (provided in this AI-PS
Element Guide) can be viewed as a health check of asset
performance again the element. Completing the Level 2 Self
Assessment will help the asset to identify areas for improvement
ahead of the Level 2 Audit.
Frequency of Level 2 Assurance
Level 2 Audits are conducted annually at each Directorate but the
frequency and duration may be adjusted to reflect either positive or
negative trends, recent audit findings, emerging risks and alignment
with other audit activities. The schedule of Level 2 audits is set in
the Directorate HSE Plan.
The frequency of Level 2 Self Assessment should also reflect how
well the asset is performing against all AI-PS Elements and be
performed no less than on an annual basis (ahead of the Level 2
Audit).
Level 3 Verification Checklist
Level 3 Verification Description
Level 3 Verification demonstrates compliance with the asset HSE
Case barriers, HSE Critical Tasks, operational procedures and other
requirements defined in the HSE Management System. These
activities provide an ongoing check that the procedures, tests and
inspections necessary to maintaining the functionality of Safety
Critical Elements and systems are completed as required so that
process risk is managed to a level that is As Low As Reasonably
Practicable (ALARP).
In summary, the Level 3 Checklists are an operational level sample
check or mini audit completed by the asset against PDO and asset
based procedures. The effectiveness of the Level 3 Verification
process is assessed during the Level 2 Self Assessment process and
ultimately via the Level 2 Audit programme.
Verification Checklists
Level 3 Verification checklists have been developed for each AI-PS
Element within PDO in order to provide a structured and consistent
approach to Level 3 Verification across all assets. The Level 3
Verification checklists are structured as a sample check or specific
and localised audit of the Element in question.
By successfully verifying that the Level 3 Verification activities are
being completed correctly it provides a strong indication that the
element is being implemented at the system level (assessed via the
Level 2 Self Assessment and Level 2 Audits).
The Level 2 Self Assessment and Level 3 Verification checklists for
this element are provided below.
Level 2 Self Assessment

SN Protocol Y /N / NA & evidence Possible approaches

15.1 Does the Operations HSE Case define HSE Review the People section of the Operations
Critical Positions (roles) and Activities HSE Case
(responsibilities) for Operations personnel to
manage the AI-PS hazards at the asset?
15.2 Do Operations staff have the required AI-PS Element Champion check of asset
competencies in accordance with PR-1029, training/competency matrix
including hazard identification and risk
assessment?
15.3 Are adequate Operations resources available to
cover activities during routine and unusual
situations (e.g. shutdown, commissioning and
start-up)?
15.4 Are adequate Operations support resources
available to covering all job functions,
particularly those identified in HSE Critical
Positions?
15.5 Is there a formal system for handovers
between shifts (co-ordinators, supervisors,
technicians, operators)?
15.6 Is the Integrated Activity Planning (IAP) process
implemented and YTT meetings, 14-day and 90-
day plans communicated across worker
groups?
15.7 Are systems describing safe/efficient operating
limits in place i.e. LOE, MOPO, FSR?
15.8 Are procedures for controlling engineering keys
and managing process software changes in
place?
15.9 Are AI-PS critical registers in place and audited
i.e. spectacle blind register, LO/LC valves
register, EPI register, passing valve register,
temporary repairs register, hose register?
SN Protocol Y /N / NA & evidence Possible approaches
15.10 Have daily Operator check-sheets been
developed for the asset?
15.11 Does the asset recognise good conduct (e.g.
employee recognition, Shukran), address poor
conduct (e.g. consequence management,
coaching), and encourage open communication
(e.g. suggestion schemes, raise concerns to line
supervisors)?
15.12 Are AI-PS targets and milestones included in
the Performance Contracts of Operations
personnel?
15.13 Are Conduct of Operations L3 Assurance Asset KPI reported to AIPSALT by element
checks carried out in line with the assets champion
defined schedule?
15.14 Do the results of Conduct of Operations L3
Assurance checks indicate an improving trend?
15.15 Are the findings of the Conduct of Operations
L3 Assurance checks used to generate
improvement activities?
15.16 Are actions identified in Conduct of
Operations L3 Assurance checks tracked to
completion by the AIPSALT and completed in a
timely manner?
AI-PSM Level 3 Conduct of Operations Audit Form

Area ___________________________________________________________________________ Date _____________

Yes No Remarks

Follow written procedures

a) Check 2 isolations

Ensure marked up PEFS are present

Is the isolation is identified on the isolation board?

If the work is classified as MAJOR is a positive isolation using

spade or blind in place?

Ensure the integrity of all EPIs are audited at an appropriate

frequency stipulated by the Production Co-ordinator

Are all isolated or LO/LC valves fitted with a correctly fitted

Pro-lock securing device?

b) Check 2 activities involving breaking containment

Was the equipment gas freed with an inter gas in accordance

with PR-1073?

Was the equipment purged with an inert gas after the

equipment was boxed up?

Was a re-instatement leak test carried out in accordance with

PR-1073 before returning the equipment to service?

If nitrogen was used for gas freeing or purging did the risk
assessment adequately cover the hazards of nitrogen?

c) Check 2 ongoing activities for sour facilities

Is the area correctly classified in terms of H2S, has it been re-

classified in line with the requirements of PR-1078? Is the
classification clearly visible for all to see?

Are H2S evacuation drills carried out monthly?

Is there always someone on the facility trained to muster

personnel?

d) Check 3 recent waivers from Operating Procedures

Are the authorised waivers available and on display at the

affected facilities?

Was the operator involved in the creation of the waiver or the

associated risk assessment?

e) Check 3 override of temporary safeguarding system forms

Has the request for the override followed the correct approval
process?

Is the override request supported by a robust risk assessment

and have any identified controls required been implemented?
 Yes No Remarks
Who normally applies the overrides in this facility and what
role does the operator play?

f) Check recent incidents

Is the operator aware of how to classify and raise a Process

Safety incident?

Are Process Safety incidents raised for unsafe acts or unsafe

conditions?

g) Top 10 procedures

Does the operator know the content of the key operating

procedures?

Follow safe practices

a) At a general level were unsafe work practices observed? Were

there any violations of LSRs?

Use qualified workers

a) Are the people carrying the appropriate licence cards for the
roles being carried out? Check HSE passports e.g. AGT.

Assign adequate resources

a) Is the number of Operators per panel appropriate for the level

of activity?

b) Are there sufficient Area Authorities for the number of permits

in force? Is there a risk assessment for any deviation from the
required ratio?

c) Is there an accountable person always on site for emergency

response (someone to manage mustering of personnel)?

Formalise communication between workers/shifts/work groups

a) Has a quality TRIC discussion taken place, and was the Area
Authority present?

b) Has a formal documented handover taken place between

operators for each shift and tour change?

c) Is the PTW tracking system valid for the days activity?

d) Did the station overview given by the operator cover ongoing

activities?

e) Are problems discussed with Supervision, Technical Authorities

and Support Specialists? Provide examples.

Adhere to safe operating limits and limiting conditions for

operators

a) Are Live Operating Envelopes fit for purpose and used

continually?

b) Is the MOPO understood and used regularly?

c) Are any Temporary Overrides fully risk assessed and controls

implemented?
 Yes No Remarks
d) Do Operators understand FSR and how to use it? Do they use
it?

Control Access and Occupancy

a) Do the station logs match the number of people on site? If the

facilities are classified as sour, are all personnel on site
entered in the access log? Are the numbers on site in line with
maxima in accordance with PR-1078? Are risk assessments in
place for any deviations?

b) For High Sour facilities does the operator know what the
Emergency Planning Zone is, and who is in it?

c) For critical high risk sour facilities, has any red zone access
been risk assessed and are personnel in these areas wearing
BA?

d) Are all doors to station control rooms secured where

necessary?

e) Are there non-authorised personnel in the Control Room or

Permit Control facility?

f) Does each individual have the correct safety equipment for

the area classification?

Formalise equipment/asset ownership and access protocols

a) Are the Spectacle blinds in the correct positions as per PEFS?

Is there a maintained register in place? Has the responsible
Supervisor audited the register?

b) Are the LO/LC valves in the correct positions as per PEFS? Is

there a maintained register in place? Has the responsible
Supervisor audited the register in accordance with PR-1086?

c) Are there any alarms inhibited or disabled without approval?

d) Is the Operator aware of any disconnected/removed/isolated

equipment? Check EPI register.

Monitor equipment status

a) Are there registers in place and being used for passing valves,
temporary repairs and hoses?

b) Are leaks identified, recorded on the daily report reported

through Fountain if appropriate, and is a remedial action in
place?

c) Do shift/tour handovers document notification of problem, or

unavailable equipment?

d) Are operators using the daily operator check sheet?

Maintain good housekeeping/lighting

a) Are work areas tidy and well lit?

b) Have any lights failed? If so, have notifications been raised?

c) Are there any distraction for the operator in the Control Room
e.g. unauthorised people, equipment, or inappropriate media?
 Yes No Remarks
Maintain labelling

a) Are the following labels in place, Ex test and inspection, valve

I.D. tags, piping colour coding, flange management tags,
equipment labels, RV tags?

Maintain Instrument and tools

a) Is all PE in the station registered and does it carry valid

inspection and maintenance records?

b) Are all portable gas monitors and SCBA systems within

calibration? Have the users carried out a self test correctly?

Emphasis observation and attention to detail

a) Check to see if notifications have been raised for leaks,

equipment failures, unsafe conditions etc.

Promote a questioning /learning attitude

a) Does the operator feel empowered to stop work or shutdown

process if he feels safety is compromised? Is safety the
number 1 priority? Does the operator challenge inefficient
working?

Train workers to recognize hazard

a) Check quality of Job HSE Plans and TRIC - did all those involved
take part? Check quality of risk assessments underpinning
waivers, overrides etc. Have all the hazards been identified
and appropriate controls put in place?

b) Have the risk been identified to the appropriate people, do

they understand the risks and the role they play? Have the
risks been accepted and approved by the appropriate people?

c) Do the people at site understand the Job HSE Plan and TRIC?

Train workers to self check and peer check

a) Does the Area Authority take part in TRIC? Does he ensure all
controls are implemented as agree?

b) Is Pause & Check used as part of the TRIC process to identify

changes to the worksite hazards once a job is underway?

c) Is STOP being used actively?

d) Are Class A permits and isolations on hydrocarbon systems

countersigned by the Production Co-ordinator?

Maintain accountability

a) Do Area Authorities and Responsible Supervisors know what

they are accountable for?

Correct deviations immediately

a) Check LOEs for prolonged periods of operating outside of

operating limits.

Auditor Name________________ Signature _______________ Indicator ________________