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Guidance on meeting expectations of

EI Process safety management framework

Element 7: Documentation, records and knowledge


management

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GUIDANCE ON MEETING EXPECTATIONS OF
EI PROCESS SAFETY MANAGEMENT FRAMEWORK

ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

1st edition

February 2014

Published by
ENERGY INSTITUTE, LONDON
The Energy Institute is a professional membership body incorporated by Royal Charter 2003
Registered charity number 1097899

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

CONTENTS
Page

Publications in this series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1.1 Documentation, records and knowledge management . . . . . . . . . . . . . . . . . . . . . . . 7
1.2 Expectations for element 7: Documentation, records and knowledge management . 7

2 Arrangements for meeting expectations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9


2.1 Descriptions of actions for each step in the logical flow diagram . . . . . . . . . . . . . . . 11

3 Suggested compliance checks and performance measures . . . . . . . . . . . . . . . . . . . . 20


3.1 Performance measure 1: Element compliance and implementation status
(EIPSS rating) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
3.2 Performance measure 2: Documentation and records development –
progress against schedule ������������������������������������������������ 22
3.3 Performance measure 3: Documents and records overdue for review and update . . 23
3.4 Performance measure 4: Documentation, records and knowledge management –
observed non-compliances ������������������������������������������������ 24
3.5 Performance measure 5: Overdue field observations . . . . . . . . . . . . . . . . . . . . . . . . 25
3.6 Performance measure 6: Incident root causes which are failures of element 7 . . . . . 26

Annexes
Annex A References and bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
A.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
A.2 Further resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

Annex B Glossary of acronyms and abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

Annex C Mapping of steps to EI PSM framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

Annex D Example report template: management and supervisory field observation . . 31

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

.PUBLICATIONS IN THIS SERIES

Guidance on meeting expectations of EI Process safety management framework


−− Element 1: Leadership, commitment and responsibility
−− Element 2: Identification and compliance with legislation and industry standards
−− Element 3: Employee selection, placement and competency, and health assurance
−− Element 4: Workforce involvement
−− Element 5: Communication with stakeholders
−− Element 6: Hazard identification and risk assessment
−− Element 7: Documentation, records and knowledge management
−− Element 8: Operating manuals and procedures
−− Element 9: Process and operational status monitoring, and handover
−− Element 10: Management of operational interfaces
−− Element 11: Standards and practices
−− Element 12: Management of change and project management
−− Element 13: Operational readiness and process start-up
−− Element 14: Emergency preparedness
−− Element 15: Inspection and maintenance
−− Element 16: Management of safety critical devices
−− Element 17: Work control, permit to work and task risk management
−− Element 18: Contractor and supplier, selection and management
−− Element 19: Incident reporting and investigation
−− Element 20: Audit, assurance, management review and intervention

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

FOREWORD

Process safety management (PSM) is vital to ensuring safe and continued operations in major accident
hazard (MAH) organisations. However, PSM is a multifaceted process, and a number of high profile
incidents since 2005 have suggested that without a holistic understanding of the various factors
required for effective PSM it can be difficult and inefficient to ensure, and measure, performance.

In 2010 the Energy Institute (EI) published High level framework for process safety management ('PSM
framework'), which aimed to define what PSM should involve. Divided into four focus areas (process
safety leadership, risk identification and assessment, risk management, and review and improvement)
and sub-divided into 20 'elements', it sets out a framework of activities MAH organisations should
undertake to ensure PSM. Each element lists a number of high level activities organisations should
meet (expectations).

EI Guidance on meeting expectations of EI Process safety management framework is a series of 20


publications ('guidelines') that build on the PSM framework. Commissioned by the EI Process Safety
Committee (PSC) each guideline captures and presents current industry good practices and guidance
on how organisations can meet the expectations set out in each element of the PSM framework.
Each guideline includes:
−− A logical flow diagram of activities (‘steps’) the organisation should undertake to
manage that element.
−− Descriptions of those steps.
−− Example performance measures (PMs) to measure the extent to which key steps have
been undertaken.
−− A list of further resources to help undertake key steps.
−− A table mapping the steps against the expectations in the PSM framework.
−− Annexes of useful information.

Readers implementing the guidance in this publication should be aware of the PSM framework and
the other publications in this series, particularly if they are a manager with oversight of the wider
implementation of PSM.

The information contained in this publication is provided for general information purposes only.
Whilst the EI and the contributors have applied reasonable care in developing this publication, no
representations or warranties, express or implied, are made by the EI or any of the contributors
concerning the applicability, suitability, accuracy or completeness of the information contained herein
and the EI and the contributors accept no responsibility whatsoever for the use of this information.
Neither the EI nor any of the contributors shall be liable in any way for any liability, loss, cost or
damage incurred as a result of the receipt or use of the information contained herein.

Suggested revisions are invited and should be submitted through the Technical Department, Energy
Institute, 61 New Cavendish Street, London, W1G 7AR. e: technical@energyinst.org

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IMPORTANT: This document is subject to a licence agreement issued by the Energy Institute, London, UK. It may only be used in accordance with the licence terms and conditions. It must not be forwarded to, or stored, or accessed by, any unauthorised user. Enquiries: e:pubs@energyinst.org t:
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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

ACKNOWLEDGEMENTS

EI Guidance on meeting expectations of EI Process safety management framework was commissioned


by the Energy Institute (EI) Process Safety Committee (PSC) and prepared by Martin Ball (Bossiney
Consulting). During this project, PSC members included:

Martin Ball Bossiney Consulting


David Bleakley ConocoPhillips
John Brazendale Health and Safety Executive
John Briggs Kuwait Petroleum International
Jonathan Carter Marsh
James Coull Total
Kenny Crighton Nexen
Peter Davidson UKPIA
Graeme Ellis ABB
Dr David Firth Chilworth Group
Peter Gedge (Chair) BP
John Henderson CB&I Lummus (BCECA)
Bob Kilford EDF Energy
King Lee (Vice-Chair) Lloyd’s Register
Keith Lewis Total E&P UK Ltd
Paul McCulloch E.ON
SreeRaj Nair Chevron
Peter O’Toole Tullow Oil
John Pond Consultant
Dr Niall Ramsden Resource Protection International
Toby St.Leger ConocoPhillips
Dr Mark Scanlon (Secretary) Energy Institute
Don Smith Eni UK

The following additional individuals are acknowledged for commenting on the drafts for consultation
of this series of publications:

Lee Allford European Process Safety Centre


Mike Beanland ABB
Amanda Cockton Health and Safety Executive
Edwin Ebiegbe Perenco
Allan Ormond ABB

Technical editing was carried out by Stuart King (EI).

Affiliations are correct at the time of contribution.

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

1 INTRODUCTION

1.1 Documentation, records and knowledge management

This guideline sets out good practices for developing and maintaining the required
documentation, records and process knowledge for effective process safety management
(PSM). Accurate records and information are essential to identify, assess and manage health,
safety and environment (HS&E) and process safety risk.
Management should ensure that the information required to support safe operation
is identified, available and up to date.

1.2 Expectations for element 7: Documentation, records and knowledge


management

Element 7 of EI High level framework for process safety management ('PSM framework')
describes eight expectations – arrangements and processes that organisations should (to an
appropriate degree) have in place in order to ensure they are appropriately managing this
aspect of PSM:
'Overview Accurate records and information are essential to identify, assess and
manage HS&E and process safety risk.
Management must ensure that the information required to support safe
operation is identified, available and up to date.

7.1 There are procedures to define, develop and maintain the required
documentation and records necessary to support robust operation and
maintenance of facilities.

7.2 Documentation and records are readily available to those who need to use
them.

7.3 Documentation and records including those kept electronically are


appropriately safeguarded.

7.4 There are procedures to ensure that documentation and records are regularly
reviewed and kept up to date as living systems.

7.5 A retention policy is defined for all documentation and records.

7.6 The required documentation and records include those generated to meet
the requirements of all other EI PSM framework expectations, such as:
−− process design considerations and basis for safe operation;
−− drawings;
−− asset register;
−− equipment records (inspection, testing, maintenance and
modification);
−− equipment specification data;
−− workplace inspection records;

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

−− work logs;
−− training and competency records;
−− incident investigation reports;
−− occupational health records;
−− operating procedures;
−− environmental authorisations;
−− planning consents;
−− relevant legislation;
−− risk assessments;
−− standards and practices;
−− hazards of materials involved in operations, and
−− product data sheets.

7.7 Arrangements for documentation, records and knowledge management are


understood and followed; understanding of arrangements and compliance
with them is regularly tested.

7.8 Compliance and performance trends are reviewed by specified levels of


management.'

This guideline provides a process, along with guidance, to help organisations meet these
expectations. It also suggests a number of compliance checks and performance measures
(PMs) to measure the extent to which key activities involved in meeting these expectations
have been or are being undertaken.

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

2 ARRANGEMENTS FOR MEETING EXPECTATIONS

Figure 1 provides a logical flow diagram for the activities that should be in place to meet the
expectations in element 7, to effectively manage documentation, records and knowledge. It
covers activities (steps) which should be undertaken by the organisation, across three phases:
set-up (preparation to manage the element); operate (management of the element); and
monitor, review and intervene (monitoring and reviewing the management of the element,
and making appropriate interventions if the element is not being managed effectively).
The flow diagram provides an example of the logical arrangement of necessary
activities. The reader should take cues from the arrangement and relationships between
steps when determining the appropriate flow design for their own organisation. The flow
diagram also shows interfaces with other elements, where this element may be dependent
upon activities that are addressed by other elements – e.g. step 2 relies on there being an
effective competence management system in place, as described in Guidance on meeting
expectations of EI Process safety management framework Element 3: Employee selection,
placement and competency, and health assurance.
At specific points in the flow diagram process, PMs are suggested. These PMs are
predominantly leading indicators designed to enable the measurement of the outputs from
the element and the level of operational compliance with the expectations. Suggested PMs
are described further in section 3.
2.1 provides guidance on the actions involved for each step, the deliverables that
should result from those actions, and the frequency at which the step should be undertaken.
It also provides more detailed guidance notes.
These steps have been mapped against element 7 expectations in Annex C. Note
that some expectations are fulfilled through several steps, and some steps help fulfil several
expectations, however all steps should be undertaken. As such, Annex C is for reference
purposes only, to demonstrate that the arrangements outlined in this guideline enable the
organisation to work towards fulfilling the requirements set out in element 7 of the PSM
framework.

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Set-up

01 02 03 04
Identify and appoint Prepare generic list of Prepare list of typical
Ensure competence of
responsible persons; define categories requiring required documentation
appointed responsible
delegated authorities for documentation and and records for each
persons
decision making records identified category

Element
3 06 05

Develop structured Define storage, retention


registers for each and review requirements
identified category

07 16
Changes to: Identify required Initiate periodic review
legislation, and documentation and records and update
industry standards

08
Review available
documentation and 3
Changes to: records against identified
processes,
requirements
assets,
work equipment,
chemicals, and 09
personnel. Plan and schedule
development of required
documentation and records

10
Develop/assemble
required documentation
and records

11
Identify and plan required
communication and training

12
Review and
approve No
Yes 2

14 13 15
Operate Implement required training Update files Communicate changes

6 6

1 17 18 19
4 Performance measurement Performance and Annual review of
and compliance checking compliance trend analysis effectiveness and
5 sustainability of element
arrangements

20
Management review and
Performance
control meetings measures
Monitor, review and intervene

Figure 1 Logical flow diagram

10

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

2.1 Descriptions of actions for each step in the logical flow diagram

Step Actions Deliverables Frequency


01 Identify and Defined roles and During implementation;
appoint responsible responsibilities. then as required.
persons; define Agreed list of
delegated responsible persons
authorities for who will:
decision making −− act as element
Identify and appoint owner, and
persons who will −− carry-out each aspect
have defined roles of the arrangements
and responsibilities for the element.
for each aspect of Defined delegated
the arrangements authorities for decision
for documentation, making.
records, and
knowledge Agreed list of delegated
management. authorities for each
identified responsible
person/position.
Guidance notes:
The senior accountable person, typically a director, business unit (BU) leader or site
manager, should ensure that accountabilities and responsibilities are assigned for each
step in the process. Typically this can be achieved by appointing an 'element owner',
who will work with line managers to agree and assign these accountabilities and
responsibilities.
Typically, the element owner should be a senior line manager.
During the implementation phase the element owner should coordinate the
implementation of the element across the organisation, BU or site on behalf of the
senior accountable person, working with other senior line managers to ensure that the
implementation is appropriately planned and resourced and that any issues are resolved.
The element owner should also ensure that delegated authorities for decision making
within the element are defined and approved.
Following implementation, during the operational phase the element owner should
work with the other senior line managers to ensure that the element continues
to operate as intended. In effect the element owner should act as a coach to the
management team and other relevant personnel, building their understanding and
confidence in the use of the element.
02 Ensure competence Training material. During implementation;
of appointed Competency then as required.
responsible persons assessment.
Training schedule.
Competent persons.

11

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


02 Define required
cont... HS&E and process
safety attributes and
example behaviours
for each level and
integrate into the
organisation’s
competency
framework (see
Guidance on meeting
expectations of
EI Process safety
management
framework Element
3: Employee
selection, placement,
competency and
health assurance).
Guidance notes:
The element owner should ensure that the required competencies are defined and
agreed for all persons with assigned roles and responsibilities within the element
and that each of these people is trained and coached appropriately to develop these
required competencies.
They should also ensure that training and development programmes and routine
personnel performance appraisals take into account these required competencies. This
should be accomplished by means of Guidance on meeting expectations of EI Process
safety management framework Element 3: Employee selection, placement, competency
and health assurance.
03 Prepare generic Reference list of typical During implementation;
list of categories categories requiring then updated as
requiring documentation and required (review
documentation and records, i.e: annually).
records −− processes;
−− assets and work
equipment;
−− chemicals, and
−− personnel.
04 Prepare list of Typical required During implementation;
typical required documentation for each then updated as
documentation and identified category, required (review
records for each approved by delegated annually).
identified category authority.
Typical required records
for each identified
category, approved by
delegated authority.

12

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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


Guidance notes:
Clear standards should be set for what documentation and records should in place
in order to support safe operation of the process and the organisation. During the
implementation phase the element owner should ensure that these are clearly defined.
As a first stage it is helpful to identify the categories within the organisation which
should have documentation and records in place in order to support a safe operation,
for example processes, assets, work equipment, chemicals or personnel. Once these
categories have been defined the required documentation and records should be
defined for each one; this may require further sub-division of these categories covering,
for example, generic process types or classes of asset or work equipment.
The categories and generic documentation and record requirements should be reviewed
and approved by personnel with the delegated authority to do so.
05 Define storage, Approved: During implementation;
retention −− Storage, access then updated as
and review control and back- required (review
requirements up requirements for annually).
each identified type
of document and
record.
−− Retention policy for
each identified type
of document and
record.
−− Review and update
frequency for each
identified type of
document and
record.
Guidance notes:
The element owner should ensure that the standards are set for how the required
documentation and records will be held and safeguarded. These standards should
address: how and where documentation and records will be held; who will be
responsible for owning and maintaining them; how they will be backed-up to avoid loss
in the event of a disaster, and how access to records will be controlled.
The standards should also establish the retention policy for each type of record, how
long they should be held for and how they should be disposed of at the end of the
defined retention period.
The element owner should also ensure that requirements for regular review and update
of documentation and records are established. The required frequency for review and
update should be set to be proportionate to the identified level of risk associated with
not having each type of documentation or record; those with higher risks should be
reviewed on a more frequent basis. Priority should be given to legal requirements
and documentation/records supporting safety critical devices or parts of the process.
Likelihood of degradation or change is also a factor which should be taken into account
when setting required review and update frequencies.

13

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


06 Develop structured Approved register During implementation;
registers for each identifying the members then updated as
identified category of each category, i.e: required (review
−− processes; annually).
−− assets and work
equipment;
−− chemicals;
−− personnel, and
−− other identified
categories.
Guidance notes:
During the implementation phase the element owner should ensure that the
organisation has comprehensive structured registers in place for each category identified
in step 4. These registers should list all members of each category, listing as a minimum
all processes, assets, work equipment, chemicals and personnel within each area of
operation.
Consideration should be given to the adequacy of identification and numbering systems
to ensure that all processes, assets, work equipment, chemicals and personnel are
uniquely identified.
It is likely that an asset register, covering assets and work equipment, will have been
developed within the maintenance management system and that personnel details
will be held in a personnel management system. The element owner should ensure
that the adequacy of any existing arrangements is confirmed and that any additional
requirements are identified.
07 Identify required Required During implementation;
documentation and documentation for each then updated as
records identified member of required (review
each category. annually).
Required records for
each identified member
of each category.
08 Review available Identified available During implementation;
documentation documentation and then updated as
and records records. required (review
against identified Identified listing of annually).
requirements required documentation
and records.
Guidance notes:
The required documentation and records should be identified for each item or person
identified in step 6, and compared with the available documentation and records in
order to identify any gaps.
The gaps in available documentation and records should be prioritised to identify the
order in which they need to be developed.
In making decisions about the requirements and priority for development, the potential
consequences and risks associated with not having the documentation or records
should be considered.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


09 Plan and schedule Approved plan During implementation;
development and schedule for then updated as
of required development of required (review
documentation and required documentation annually).
records and records:
−− what needs to be
done;
−− assigned resource;
−− when it will be done,
and
−− assigned
responsibility for
delivery.
Guidance notes:
The element owner should ensure that a plan and schedule are in place for the
development of the required documentation and records. The plan and schedule should
identify:
−− what will be done;
−− when it will be done;
−− the resource assigned to the work, and
−− responsibility for delivery of each item.
The schedule should be reviewed and agreed with the line managers of personnel who
will be required to participate in the work. It should also be reviewed and approved by a
line manager with the authority to do so.
The schedule provides a basis for monitoring progress. Accountable managers should
compare actual with scheduled progress and make appropriate interventions to correct
any deviations.
On an on-going basis, the need to update documentation and records may be initiated
by a number of factors such as changes to:
−− processes;
−− assets or work processes;
−− personnel or organisation;
−− products and services;
−− chemicals;
−− legislation, industry or company standards.
10 Develop/ Required As required by the
assemble required documentation and schedule.
documentation and records developed in
records full and in line with the
agreed schedule.

11 Identify and Required As required by the


plan required communication and schedule.
communication and training to ensure that
training necessary personnel are
appropriately aware and
competent.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


Guidance notes:
The development of the required documentation and records should be carried out in
line with the agreed schedule.
The development of the required documentation and records should involve personnel
with a good understanding of the subject matter.
In parallel with the development of the documentation and records it should be
considered who needs to be aware of the new documentation and the requirement to
maintain records; these needs should be added to communication plans. Additionally
any training needs should be identified and incorporated into training plans.
12 Review and Approved : As required by the
approve −− completed schedule.
Review and approve documentation and
by persons with the records;
delegated authority −− proposed
to do so: communication, and
−− completed −− proposed training.
documentation
and records;
−− proposed
communication,
and
−− proposed training.
Guidance notes:
Completed documentation and records, together with the associated communication
and training plans, should be reviewed and approved by an appropriate line manager.
The line manager approving the completed documentation should have an appropriate
level of competence and delegated level of authority.
The reviewing and approving line manager should consider the quality of the completed
documentation; i.e. is it thorough and is it clear and easily understandable. The line
managers may need to take specialist advice to enable them to make this judgement.
The reviewing and approving line manager should also consider the suitability and
feasibility of the identified communication and training plans, questioning whether they
can be implemented and whether the assigned line manager accepts the responsibility
to ensure that they are implemented.
13 Update files Files updated with As required by the
Update files with current versions of schedule.
current versions of required documentation
documentation and and records.
records. Files stored, backed-up
and access controlled in
line with requirements.
14 Implement required Required training As required by the
training implemented in full and schedule.
on schedule.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


15 Communicate Required As required by the
changes communication schedule.
Implement required implemented in full and
communication. on schedule.
Guidance notes:
Following approval of the completed documentation and required records, the files
should be updated with the latest versions.
The identified communication and training plans should be implemented in line with the
required schedule. It is likely that any required training would be implemented by means
of Guidance on meeting expectations of EI Process safety management framework
Element 3: Employee selection, placement and competency and health assurance.
The line manager accountable for the implementation of the required communication
and training should continue to monitor and review the compliance with, and
effectiveness of, the communication and training.
16 Initiate periodic List of documentation As required by the
review and update with identified due schedule.
dates for required
review and update.
Guidance notes:
Documentation and records should be reviewed on a regular basis, as defined in step 5,
to identify whether there is any need for them to be updated. This need may arise as a
result of a number of factors which may include changes to:
−− processes;
−− assets or work processes;
−− products and services;
−− personnel or organisation, and
−− legislation, industry or company standards.
Documentation and records should have been updated during the implementation of
these changes (see Guidance on meeting expectations of EI Process safety management
framework Element 12: Management of change and project management). However,
there should be periodic checks that nothing has been missed and to ensure that the
documentation and records are appropriate and up to date.
17 Performance Defined PMs. As required by the
measurement PMs generated in line schedule.
and compliance with the schedule.
checking
Compliance checking
Establish and programme.
implement PMs.
Completed compliance
Establish regular checks.
management
and supervisory Identified necessary
compliance checks. interventions.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


Guidance notes:
A systematic set of PMs should be defined in order to enable each BU or site to monitor
and confirm compliance with the element and to draw attention to any areas of non-
compliance.
In order to maintain effective control, the element owner should ensure that
accountability for performance against each PM is clearly identified, and that the
accountable person understands the interventions that need to be made to correct
deviations in performance against the PM.
The element owner should ensure that PMs are reviewed by an appropriate level of
management on a routine scheduled basis.
Suggested PMs are defined in section 3.
18 Performance and A report on trends Monthly.
compliance trend identified, for review:
analysis −− at appropriate
PMs and findings management
from compliance meetings;
checks are analysed −− by the BU executive,
to identify any and
emerging underlying −− by the company
trends. executive.
Guidance notes:
Suggested PMs are identified in section 3, which should allow the BU or site to monitor
compliance with the element. This is an important aspect of management control but it
does not provide the whole picture.
It should be ensured that findings, compliance checking and performance monitoring
are reviewed and analysed in order to identify any underlying trends. The trends to
be monitored and analysed should be adapted according to performance and the
issues being managed during any particular time period. However, the key issue is to
ensure that resource is assigned to carry out this monitoring and analysis and that this
trend analysis is carried out on a routine basis and presented for review at appropriate
management meetings.

19 Annual review A report identifying Annually.


of effectiveness issues requiring
and sustainability resolution, and
of element opportunities
arrangements. to enhance the
Review of the arrangements.
arrangements to
check that they
are functioning as
intended and are still
fit for purpose.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

Step Actions Deliverables Frequency


Guidance notes:
The element owner should initiate an annual review of the element in order to check
that it is still functioning as intended and that it is still fit for purpose, identifying any
issues requiring resolution, or any opportunities to enhance the implementation of the
element.
The element owner should ensure that appropriate employees and employees’
representatives are involved in developing input to this review.

20 Management PMs and trend analysis Monthly.


review and control reviewed:
meetings −− at appropriate
Review meetings with management
the appropriate levels meetings;
of management. −− by local line
management;
Systematic review of −− by the BU executive,
defined PM sets. and
Review emerging −− by the company
issues identified by executive.
the analysis of trends. Appropriate
Manage issues interventions to correct
and opportunities deviations from required
identified by annual performance.
review of the process. Initiation of appropriate
Identify appropriate actions to address
interventions. findings from the
annual review.
Guidance notes:
The element owner should ensure that the review of the PMs is incorporated into
appropriate management control meetings. It is likely to be necessary to incorporate
the PMs into meetings at a number of different levels. For example, they may need to
be incorporated into executive meetings and into senior management team meetings.
Understandably, the scope of the PM should be matched to the area of the business
which is being reviewed at each meeting.
The management control meetings should focus on deviations from the required
performance, identifying necessary interventions to correct performance.
These review and control meetings should be incorporated into the design of the
governance arrangements.
The PMs and the output from these management control meetings may provide input
to appropriate HS&E committees.

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

3 SUGGESTED COMPLIANCE CHECKS AND PERFORMANCE


MEASURES

This guideline provides a set of suggested implementation and operational PMs.


The suggested implementation PMs can be used during the implementation phase to
measure and monitor progress with the implementation of the arrangements for leadership,
commitment and responsibility.
The suggested operational PMs can be used to measure compliance with the element
as part of normal operation. The reader should refer to Figure 1 to indicate which PMs are
relevant to which steps.
The suggested measures identify aspects of performance that should be controlled
in order to assure the integrity of the operation. In order to be controlled they should be
measured by someone in the organisation; if they aren’t measured, they are unlikely to be
controlled.
The measurement regime should be appropriate for the business, taking into account
the risk to the business associated with each parameter being out of control.
The required frequency of measurement and checking may vary according to the
level of demonstrated performance: if the performance of a parameter is demonstrated to be
under control then the measurement and checking interval may be extended. However, if the
performance of the parameter is shown to be unacceptable, the interval should be reduced.
It should be ensured that there is a frequency of measurement and checking which assures
an appropriate level of control.

Table 1 Performance measures for element 7

No. Type Performance measure


1 Compliance and implementation Element compliance and implementation
status (EIPSS rating)
2 Implementation Documentation and records development –
progress against schedule
3 Operational Documents and records overdue for review
and update
4 Operational Documentation, records and knowledge
management – observed non-compliances
5 Operational Overdue field observations
6 Outcome Incident root causes which are failures of
element 7

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3.1 Performance measure 1: element compliance and implementation


status (EIPSS rating)

This PM enables management to monitor the implementation and compliance of this element
of the EI PSM framework. It makes use of the EI Process Safety Survey (EIPSS) to enable the
business to carry out a systematic self-assessment of their compliance with the expectations
of element 7.
The EIPSS can be used for a baseline assessment of compliance, which can then
be updated as those responsible close each of the individual identified gaps. In this way
it provides management with an easily developed, continuously updated assessment of
implementation and compliance.
The line manager accountable for implementation should make a corrective
intervention if the actual progress falls below plan. It is likely the required interventions would
be either to adjust priorities to create space to allow this work to be done, to make additional
resource available, or to reset the schedule to reflect what can be achieved realistically with
the assigned resource.

Table 2 Element compliance and implementation status (EIPSS rating) – PM overview

Type Required data Representation


Compliance and By month: Line and bar graph:
implementation −− current element 7, target −− target overall element
EIPSS overall rating; rating (line);
−− current element 7, actual −− overall element rating (bar);
EIPSS overall rating; −− documented arrangements
−− current element 7, EIPSS rating (line), and
documented arrangements −− implementation rating
rating, and (line).
−− current element 7, EIPSS
implementation rating.

4.0
3.5
3.0
EIPSS rating

2.5
2.0
1.5
1.0
0.5
0.0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Overall status Implementation Documented arrangements Target overall status

Figure 2: Suggested presentation of PM 1: Compliance and implementation status


(EIPSS rating)

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3.2 Performance measure 2: Documentation and records development –


Progress against schedule

This PM enables management to monitor implementation progress, tracking the identified


number of documents and records required, the schedule for their development and progress
against schedule.
The line manager accountable for implementation should make a corrective
intervention if the actual progress falls below plan. It is likely the required interventions would
be either to adjust priorities to create space to allow this work to be done, to make additional
resource available, or to reset the schedule to reflect what can be achieved realistically with
the assigned resource.

Table 3 Documentation and records development – progress against schedule – PM


overview

Type Required data Representation


Implementation By month: Line bar:
−− Identified number of −− identified number of
required documents and required documents and
records. records (bar);
−− Scheduled number of −− number scheduled (line),
documents and records to and
be developed. −− number completed (bar).
−− Actual number of
documents and records
developed.
Documentation and records development status
120

100

80
Number

60

40

20

0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Required documentation Completed Scheduled progress


and records

Figure 3 Suggested presentation of PM 2: Documentation and records development


– progress against schedule

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3.3 Performance measure 3: Documents and records overdue for review


and update

This PM enables management to monitor the number of documents and records that are
overdue for review and update, tracking the number that are overdue for less than three
months and the number that are overdue by more than three months.
The graphical representation of this PM is likely to be supplemented by a listing of the
overdue documents and records, together with the responsible line manager in each case.
The accountable line manager should make an intervention if there are any
documents and records which are overdue for review and update. It is likely the required
intervention would be either to adjust priorities to create space to allow this work to be
done, to make additional resource available, or to reset the schedule to reflect what can be
achieved realistically with the assigned resource.

Table 4 Documents and records overdue for review and update – PM overview

Type Required data Representation


Operational By month: Stacked bar:
−− Number of documents and −− more than three months
records overdue for review overdue, and
and update by more than −− less than three months
three months. overdue.
−− Number of documents and
records overdue for review
and update by less than
three months.

5
No. overdue

0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

< 3 month > 3 month

Figure 4 Suggested presentation of PM 3: Documents and records overdue for


review and update

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3.4 Performance measure 4: Documentation, records and knowledge


management – Observed non-compliances

This PM enables management to monitor the number of observed non-compliances with


required documentation, records and knowledge management, tracking the number of
observed major non-compliances and the number of observed minor non-compliances.
The graphical representation of this PM is likely to be supplemented by a listing of the
observed major non-compliances together with the responsible line manager in each case.
The accountable line manager should make an intervention if there is a prolonged
increasing trend in the number of non-compliances. It is likely that the intervention would
be to question what additional support or resources would be required to correct the trend.

Table 5 Documentation, records and knowledge management – observed


non-compliances – PM overview

Type Required data Representation


Operational By month: Stacked bar:
−− Number of observed major −− major non-compliances,
non-compliances. and
−− Number of observed minor −− minor non-compliances.
Observed non-compliance
non-compliances. with required
documentation
7
6
No. of non-compliances

5
4
3
2
1
0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Minor non-compliance Major non-compliance

Figure 5 Suggested presentation of PM 4: Documentation, records and knowledge


management – observed non-compliances

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3.5 Performance measure 5: overdue field observations

This PM enables management to monitor whether the scheduled management and


supervisory field observations have been carried out, tracking the number of overdue field
observations. It is likely that this PM would be supported by a list showing each of the
overdue field observations and who the responsible line managers are in each case.
The accountable line manager should make an intervention if there are any overdue
field observations.
It is likely that the required intervention would be to directly request the appropriate
line manager to ensure that the outstanding field observations are completed before the
next management control meeting and to question why they were not done and what needs
to be done to ensure that they are done in future. Typically this may require adjustment of
priorities reassigning work activities to create space to allow this work to be done. If the
situation continues for some time it is likely to be indicative of an underlying issue with either
resource levels or time planning.

Table 6 Overdue field observations

Type Required data Representation


Operational By month: Bar graph
−− The number of
overdue management
and supervisory field
observations.
Overdue field observations
7

5
No. overdue

0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Figure 6 Suggested presentation of PM 5: Overdue field observations

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3.6 Performance measure 6: Incident root causes which are failures of


element 7

This PM enables management to monitor the trend of the number of times a failure of
some aspect of element 7 is identified as a root cause of an incident (Guidance on meeting
expectations of EI Process safety management framework Element 19: Incident reporting and
investigation provides guidance on how root causes should be aligned to failures of EI PSM
framework elements). This information should assist line managers to understand whether
their arrangements for meeting the expectations of element 7 are achieving the required
outcome.
A constant or increasing number of root causes associated with a failure of this
element would indicate that there is a need to review the effectiveness of the arrangements
and their implementation.

Table 7: Incident root causes which are failures of element 7 – PM overview

Type Required data Representation


Outcome (lagging By month: Stacked bar:
indicator) −− Number of incident root −− very serious incidents;
causes which are failures of −− serious incidents, and
element 7, categorised as −− incidents.
root causes of:
−− very serious incidents;
−− serious incidents, or
Incident root causes
−− incidents.
which are failures of element 7
14

12

10
No. of incidents

0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Incidents Serious incidents Very serious incidents

Figure 7 Suggested presentation of PM 6: Incident root causes which are failures of


element 7

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

ANNEX A
REFERENCES AND BIBLIOGRAPHY

A.1 References

EI, High level framework for process safety management


http://www.energyinst.org/psm-framework

A.2 Further resources

This section contains a non-exhaustive list of further resources to help organisations


implement element 7. Resources include pertinent guidance publications, codes of practice,
standards, and practical tools.

Description Step
HSE Developing process safety indicators, A step-by-step guide for the 17, 18
chemical and major hazard industries, HSG254,
http://books.hse.gov.uk/hse/public/saleproduct.
jsf?catalogueCode=9780717661800
HSE HSE website documentation, 07
http://www.hse.gov.uk/comah/sragtech/docs.htm

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ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

ANNEX B
GLOSSARY OF ACRONYMS AND ABBREVIATIONS

BU business unit
EIPSS Energy Institute Process Safety Survey
HSE Health and Safety Executive
HS&E health, safety and environment
MAH major accident hazard
PM performance measure
PSC process safety committee
PSM process safety management

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IMPORTANT: This document is subject to a licence agreement issued by the Energy Institute, London, UK. It may only be used in accordance with the licence terms and conditions. It must not be forwarded to, or stored, or accessed by, any unauthorised user. Enquiries: e:pubs@energyinst.org t:
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ANNEX C
Mapping of steps to EI PSM framework

Table C1 Mapping of steps to EI PSM framework expectations for element 7

GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK


Step number
Expectation

ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT


01 02 03 04 05 06 07 08 09 10 11 12 13 14 15 16 17 18 19 20
7.1 There are procedures to define, develop and maintain
the required documentation and records necessary to
support robust operation and maintenance of facilities.
7.2 Documentation and records are readily available to those
who need to use them.
7.3 Documentation and records including those kept
electronically are appropriately safeguarded.
7.4 There are procedures to ensure that documentation and
29

records are regularly reviewed and kept up to date as


living systems.
7.5 A retention policy is defined for all documentation and
records.
7.6 The required documentation and records include those
generated to meet the requirements of all other EI PSM
framework expectations, such as:
process design considerations and basis for safe
operation;
drawings;
asset register;
equipment records (inspection, testing, maintenance and
modification);
equipment specification data;
workplace inspection records;
work logs;
training and competency records;
incident investigation reports;
occupational health records;
GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT
20
19
18
17
16
15
14
13
12
Step number
11
10
09
08
07
06
05
04
03
02
01

knowledge management are understood and followed,


Arrangements for documentation, records and process

understanding of arrangements and compliance with

Compliance and performance trends are reviewed by


hazards of materials involved in operations, and
Expectation

specified levels of management.


environmental authorisations;

standards and practices;

them is regularly tested.


operating procedures;

product data sheets.


relevant legislation;
planning consents;

risk assessments;
cont.
7.6

7.7

7.8
30
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IMPORTANT: This document is subject to a licence agreement issued by the Energy Institute, London, UK. It may only be used in accordance with the licence terms and conditions. It must not be forwarded to, or stored, or accessed by, any unauthorised user. Enquiries: e:pubs@energyinst.org t:
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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 7: DOCUMENTATION, RECORDS AND KNOWLEDGE MANAGEMENT

ANNEX D
EXAMPLE REPORT TEMPLATE: MANAGEMENT AND
sUPERVISORY FIELD OBSERVATION

Management and supervisory field observation report


Location: Date:
Work group leader: Observer:
Rating Comments
1 2 3 4 n/a
Is the documentation
suitable and sufficient?
Is the required
documentation available
and in date?
Are the records suitable
and sufficient?
Are the records complete
and up to date?
Are the personnel
aware of the available
documentation?
Are the personnel aware
of the required records?
Do the personnel have
ready access to the
documentation?
Do the personnel have
ready access to the
records?
Are the storage and
retention requirements
being met?
1 = Major deficiency identified 2 = Minor deficiency identified
3 = Meets expectations 4 = Exceeds expectations
Note: Organisations should define what will be considered as major and minor deficiencies;
the use of the risk matrix may assist with this.

31

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IMPORTANT: This document is subject to a licence agreement issued by the Energy Institute, London, UK. It may only be used in accordance with the licence terms and conditions. It must not be forwarded to, or stored, or accessed by, any unauthorised user. Enquiries: e:pubs@energyinst.org t:
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This publication has been produced as a result of
work carried out within the Technical Team of the
Energy Institute (EI), funded by the EI’s Technical
Partners and other stakeholders. The EI’s Technical
Work Programme provides industry with cost
effective, value adding knowledge on key current
and future issues affecting those operating in the
Energy Institute energy sector, both in the UK and beyond.
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IMPORTANT: This document is subject to a licence agreement issued by the Energy Institute, London, UK. It may only be used in accordance with the licence terms and conditions. It must not be forwarded to, or stored, or accessed by, any unauthorised user. Enquiries: e:pubs@energyinst.org t:
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