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REGULATORY
2023 Tier 1 OSR MS Audit for Offshore Assets -
SK311
Consultant:
Vysus Malaysia Sdn Bhd
(formerly known as Lloyd’s Register Technical Services Sdn Bhd)
REVISION HISTORY
Revision
Rev. Revised Paragraphs Reason for Revision
Description
DISCLAIMER STATEMENT
The information provided by PTTEP is confidential and shall only be used by the party to whom it is disclosed to (“the Receiving
Party”). The Receiving Party shall not disclose, publish, reproduce or reveal the information received to any other third party
whatsoever except with the specific prior written authorization of PTTEP. The Receiving Party shall within five (5) days from
notice from PTTEP return or destroy (upon instruction of PTTEP) all confidential Information furnished by PTTEP.
The Receiving Party shall also take such precautions as are reasonably necessary to protect the confidential information,
including taking measures to prevent loss, theft and misuse.
The Receiving Party shall fully indemnify and keep PTTEP at all time fully indemnified from and against any loss or disclosure of
confidential information and from all actions, proceedings, claims, demands, costs, awards and damages arising directly or
indirectly as a result of such unauthorized disclosure.
TABLE OF CONTENTS
1.0 PURPOSE
This document describes the overall scope and understanding of OSR MS assurance/audit*;
detailing high-level objectives, scope, roles and responsibilities, methodology and references.
The objectives of the OSR MS assurance are:
i. To verify compliance to OSR MS requirements to achieve AIR and HSE excellence
thorough PTTEP Malaysia facilities
ii. To determine compliance to regulatory, corporate and Petronas requirements
iii. To highlight issues and concerns, and provide recommendations for continuous
improvement
This document is applicable to all PTTEP Malaysia Offshore assets only.
Note: The term “audit” and “assurance” are interchangeable in this Terms of Reference
document
2.0 BACKGROUND
A Joint Task Force between PETRONAS and DOSH was established to introduce a new
framework for upstream operations that allows for partial industry self-regulation for managing
and sustaining safe operation to the upstream facilities by integrating AIR management
system and HSEMS. The OSR MS effectively gave PETRONAS the mandate to regulate and
oversee the management, safe operation and integrity of all upstream assets and facilities in
Malaysian waters on behalf of DOSH.
For equipment associated with offshore operations in Malaysia, specific provisions have been
given several conditional exemptions by DOSH to the FMA 1967 (Section 19 and 36) and the
whole of the Factory & Machinery (Notification, CF & Inspection) Regulations. In giving
approval to these exemptions, DOSH requires all offshore operations to abide with selected
requirements stipulated in the FMA 1967 via a “self-regulation” approach.
OSR MS regulates PSC/RSC to meet the Malaysia Statutory and PETRONAS requirements
in a systematic and standardized manner to ensure integrity and reliability of Malaysian
upstream facilities whilst safeguarding the health and safety of the personnel. Figure 1 shows
how the OSR MS relates to the Statutory and Regulatory requirements and PETRONAS
guidelines. For the purposes of and in relation to the implementation of the OSR, PSC/RSC
shall comply with the OSHA 1994, the FMA 1967 (and Orders of Exemptions) together with
the other regulations such as PSMA 1984 and PDA 1974, in combination with other contract
obligations as outlined in the latest PETRONAS Procedures and Guidelines for Upstream
Activities (PPGUA).
The Integrated Operational Asset Integrity Assurance (IOAIA) is introduced to fulfil the needs
of OSR MS matters in relation to the audit, as this will ensure the provision of a structured
system for effective management of facilities, as well as the operationalization of the OSR MS
elements.
The IOAIA is a platform that aims to achieve asset governance excellence by providing
comprehensive assessment for system effectiveness, gap analysis for continuous
improvement and system sustenance. Asset integrity inputs from IOAIA will provide added
value to process enhancement and will be set as best practice for benchmarking and
knowledge-sharing to promote effective management of facilities.
Petronas Procedures & Guidelines for Upstream Activities (PPGUA) PPGUA 4.1
Integrated Operational Asset Integrity Assurance (IOAIA) Manual MY MPM POM X P 08 001 O
4.0 DEFINITION
4.1 Acronym
For ease of reference, a table of Acronym is provided below:
Term Definition Term Definition
AIR Asset Integrity & Reliability OSR Offshore Self-Regulation
Control of Industrial Major Offshore Self-Regulation
CIMAH OSR MS
Accidents Hazards Management System
CM Corrective Maintenance PDA 1974 Petroleum Development Act 1974
Computerized Maintenance PETRONAS PETRONAS Malaysia Petroleum
CMMS
Management System MPM Management
CP Cathodic Protection PHA Process Hazard Analysis
PETRONAS Procedures and
DCS Distributed Control System PPGUA
Guidelines for Upstream Activities
Department of Safety and Petroleum Safety Measures Act
DOSH PSMA 1984
Health 1984
Escape, Evacuation
EERA PSC Production Sharing Contract
Rescue Analysis
Equipment Integrity
EIAC PSV Pressure Safety Valve
Assessment Certificate
Emergency Systems
ESSA P&ID Piping and Instrumentation Diagram
Survivability Assessment
Fire and Explosion Risk
FERA QRA Quantitative Risk Assessment
Analysis
FMA 1967 Factories Machinery Act RBI Risk Based Inspection
HER Hazard & Effect Register RCFA Root Cause Failure Analysis
Hazard & Effect
HEMP RSC Risk Service Contract
Management Process
Responsibility, Accountability,
HMI Human Machine Interface RACI Chart
Consult and Inform Chart
Health, Safety and
HSE SCE Safety Critical Element
Environment
Health, Safety and
Surface Controlled Subsurface
HSEMS Environment Management SCSSV
Safety Valve
System
4.2 Language
In this document, the words may, should, and shall have the following meanings:
x All certificated machinery is fit and provided with Equipment Integrity Assessment
Certificate (EIAC).
x Inspection, Testing and Preventive Maintenance (ITPM) tasks and intervals for SCE and
non-SCE equipment are populated in CMMS and executed accordingly.
x Identify all Major Accident Hazards and implement effective risk control measures in all
process related activities to eliminate, prevent or reduce risk to a level As Low As
Reasonably Practicable (ALARP).
SCE are the key safety plant, systems and equipment required to manage Major Accident
Hazards. The definition given in The Offshore Installations (Safety Case) Regulations 2005
(United Kingdom) of a Safety Critical Element is:
“Such parts of an installation and such of its plant (including computer programs), or any part
there:
The eight (8) IOAIA elements derived from SCE are as follow:
1) Structural Integrity
2) Process Containment
3) Ignition Control
4) Detection Systems
5) Protection Systems
6) Shutdown Systems
7) Emergency Response
8) Lifesaving
All the elements above will be audited against its Performance Standards (PS).
List of the assets’ applicable IOAIA Elements/ SCEs that will be covered under this audit are
listed in Table 3 based on Operation Safety Critical Element (SCE) and Performance Standard
(PS):
• South Acis (SA) – Latest excel version Rev 0
• Permas (PRPA) - Latest excel version Rev 0
List of IOAIA Elements/ SCEs distributed by discipline is listed in Table 4.
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Substructure &
Structural/ Facilities Engineering Structural
1 Structural SI001 Foundation, Including Y Y Y Y
Marine (Structural) Integrity
Hull Structure
Asset Integrity (Structural
Integrity) Structural
2 Structural Structural SI002 Topside Structure Y Y Y Y
Asset Integrity (Integrity Integrity
Inspection)
Maintenance (Mechanical)
Maintenance / Facilities
Structural Heavy Lift Cranes and
3 Static Static Asset Integrity (inspection SI003 Y Y Y Y
Integrity Mechanical Handling
Integrity) for NDT
Warehouse / Logistic
Asset Integrity (Integrity
Inspection) Process
4 Static Static PC001 Pressure Vessels Y Y Y N
Asset Integrity (Anomaly Containment
Management)
Asset Integrity (Integrity
Inspection)
Asset Integrity (Pressure
Process
5 Static Static Equipment) PC002 Heat Exchangers Y Y Y N
Containment
Production
Asset Integrity (Anomaly
Management)
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Operations Process
6 Rotating Rotating PC003 Rotating Equipment Y Y Y N
Maintenance Containment
Asset Integrity (Pressure
Integrity) Process
7 Static Static PC005 Piping Systems Y Y Y Y
Asset Integrity (Anomaly Containment
Management)
Operation
Production Operation
Facilities Engineering
Maintenance Process
8 Pipeline Pipeline PC006 Pipelines and Risers Y Y Y N
Production Containment
Inspection
SSHE
Asset Integirty
Relief System (PRV,
Process
9 Static Static Maintenance PC007 PSV, PVV and Burst Y Y Y Y
Containment
Disc)
Process Wells’ Hydrocarbon
10 Wells Wells Production (Operations) PC008 Y Y Y N
Containment Containment
Asset Integrity (Integrity Process Gas Tight Floors and
11 HSE Structural PC010 Y N N N
Inspection) Containment Walls
Hazardous Area
12 HSE HSE Maintenance Ignition Control IC001 Y N Y N
Ventilation
Non- Hazardous Area
13 HSE HSE Maintenance Ignition Control IC002 Y Y Y Y
Ventilation
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Certified (Ex Rated)
14 Electrical Electrical Asset Integrity Ignition Control IC003 Y Y Y N
Electrical Equipment
Maintenance Electrical Earthing
15 Electrical Electrical Ignition Control IC005 Y Y Y Y
(Electrical) / Asset Integrity Continuity
Fuel Gas Purge
16 Process Instrument Asset Integrity (E&I) Ignition Control IC006 Y Y Y N
System
Miscellaneous
17 Static Static Maintenance Ignition Control IC008 Ignition Control Y Y Y Y
Components
Flare Tip Ignition
18 Instrument Instrument Operation / Maintenance Ignition Control IC009 Y Y Y N
System
Offshore Production /
Detection Fire and Gas
19 Instrument Instrument Maintenance DS001 Y Y Y Y
Systems Detection
Asset Integrity
Facility Engineering - Detection
20 Instrument Instrument DS002 Security Systems Y Y Y Y
Telecommunication Systems
Protection
21 HSE HSE Operation / Maintenance PS001 Deluge Systems N N Y N
Systems
Fire Water Pumps
Protection
22 HSE Rotating Operation / Maintenance PS004 (Incl. Caissons, Tank N N N Y
Systems
and Supports)
Operation / Maintenance Protection Fire Main and other
23 HSE Static PS005 N N Y Y
SSHE Systems Distribution System
Asset Integrity (Structural Protection Passive Fire
24 HSE Structural PS006 Y Y Y Y
Integrity) Systems Protection (Incl.
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Doors, Wallsand
Penetrations)
Operation / Maintenance Protection Gaseous Fire
25 HSE Rotating PS007 Y N Y Y
3rd party Systems Protection Systems
Protection Fine Water Spray
26 HSE Rotating Operation / Maintenance PS008 Y Y Y Y
Systems Systems
Protection Chemical Injection
27 Process Pipeline Production Operations PS013 Y Y Y N
Systems Systems
Protection Navigation Aids
28 Electrical Electrical Maintenance (Electrical) PS014 Y Y Y Y
Systems (Aircraft)
Shutdown Emergency Shutdown
29 Instrument Instrument Maintenance SD001 Y Y Y Y
Systems (ESD) Control System
Emergency
Offshore Production / Shutdown
30 Instrument Instrument SD002 Depressurisation Y Y Y N
Maintenance Systems
(Blowdown)
Shutdown
31 Wells Wells Operations SD004 Well Isolation Y Y Y N
Systems
Shutdown Pipeline Isolation
32 Instrument Pipeline Production / Maintenance SD005 Y Y Y N
Systems Valve (Riser)
Shutdown Emergency Shutdown
33 Instrument Instrument Production / Maintenance SD006 Y Y Y N
Systems Valves (ESDV)
Shutdown
34 Process Instrument Operation / Maintenance SD009 Instrument Air Y N N N
Systems
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Temporary Refuge
Emergency
35 HSE HSE SSHE / Operations ER001 (TR) / Primary Muster Y Y Y Y
Response
Areas
Production Emergency
36 HSE HSE ER002 Escape Routes Y Y Y Y
SSHE Response
Emergency Emergency / Escape
37 Electrical Electrical Maintenance Electrical ER003 Y Y Y Y
Response Lighting
Operations / Maintenance Internal, External and
Emergency
38 Instrument Instrument Facility Engineering - ER004 Emergency Y Y Y Y
Response
Telecommunication Communication
Emergency Uninterruptable
39 Electrical Electrical Maintenance (Electrical) ER005 Y Y Y Y
Response Power Supply (UPS)
Emergency Power
Emergency
40 Electrical Electrical Production / Maintenance ER007 (Incl. Generation and Y N N Y
Response
Distribution)
Emergency Manual Fire Fighting
41 HSE HSE Operations / SSHE ER008 Y N N N
Response Equipment
Emergency Process Control and
42 Instrument Instrument Asset Integrity (E&I) ER009 Y Y Y N
Response Alarms
Bunding and Drains
Emergency
43 Process Static Operations ER010 (Hazardous and Non- Y Y Y Y
Response
Hazardous)
Oil Spill Contigency
Emergency
44 HSE HSE Operations / SSHE ER011 (Oil Boomsand N Y Y Y
Response
Dispersants)
Executing
Auditor
Discipline SCE
No Discipline SME Person in charge SCE Group SCE Sub Group PRPA SASA SAPA SAAA
(1) (*if Code
applicable)
Personal Survival
45 HSE HSE SSHE Lifesaving LS001 Y Y Y Y
Equipment (PSE)
Rescue Facilities (incl.
46 HSE HSE SSHE Lifesaving LS002 Standby Vessel / Y Y Y Y
MOB Boat / FRC)
47 HSE HSE SSHE / Maintenance Lifesaving LS003 TEMPSC/ Lifeboats N N N Y
Alternate Means of
SSHE
Escape (Liferafts,
48 HSE HSE Maintenance/Appointed Lifesaving LS004 Y Y Y Y
Scramble Nets and
Vendor
Ladders to Sea)
Management Process Safety
49 PSM PSM PSM MA007 Y Y Y Y
Assurance Management
50 Wells Wells Wells Wells Integrity WI001 Wells Integrity Y Y Y Y
Note:1. Disciplines highlighted in this column are default auditors of the SCEs.
2. Management Assurance elements (MA001,02,03,04,05, and 06) are captured as part of 2021/22 audit campaign for general PTTEP management systems.
Static & Lifting Equipment Specialist SI003, PC001, PC002, PC005, PC007, IC008, PS005, ER010
Instrumentation Specialist IC006, IC009, DS001, DS002, SD001, SD002, SD006, SD009 (PRPA only), ER004, ER009
ER001, ER002, ER008 (PRPA only), ER011, PS001, IC001, IC002, LS001, LS002, LS003 (SAAA
HSE Specialist
only), LS004
Section
Work Activity Key Task Remarks / Duration
Details
Pre-Audit
Sufficient notification
Communication between PTTEP
Notification to period will be
Regulatory and Asset Team. Outline of 6.2
Auditee provided to Asset
audit schedule and facility.
Team.
Engagement between Assessor and
Kick Off Auditee where Terms of Reference 1 day 6.3
(TOR) is explained.
Audit
Review documents as listed in
checklist and any additional
Data Analysis & documents as required. Interview with
1-2 weeks 6.5
Interviews key personnel to establish overall
understanding and status of
implementation.
Site visit to verify consistency of
information /understanding and
Site Verification 1-2 days offshore 6.6
physical evidence to demonstrate
effectiveness of program.
Section
Work Activity Key Task Remarks / Duration
Details
Findings Verification
Clarification
Validation on findings and its
Session with 1-2 days 6.7
severity rating.
SME/Asset team
Presentation and reporting
Closing Meeting with PTTEP
management where all
Exit Meeting stakeholders agree and 1 day 6.8
endorse audit findings and proposed
recommendations
Agreed timeline
Final Report Final report issuance 6.8
by all parties
High (H) x High priority issue which requires immediate attention for the
Management. There is a serious breakdown on internal control,
governance, and risk management that if not mitigated may lead
to:
o Substantial losses, possibly in conjunction with other
weaknesses in the control framework or the organizational
entity or process being audited
o Serious HSE or reputation damage
o Significant adverse regulatory impact, such as loss of
operating licenses or material fines.
x Breakdown in primary and secondary controls.
x Gaps are pervasive and systemic.
Medium (M) x Medium priority issue which requires timely attention from the
Management. There is breakdown on internal control,
governance, and risk management that if not mitigated may lead
to:
o Financial losses (stipulated levels)
o Adverse regulatory impact, such as fines
o Reputation damage
x Breakdown in primary control but secondary control exists and
functioning.
x Gaps are isolated and not pervasive.
Consultant -
1 Danial Khan Lead Auditor Lead Auditor
Vysus
Hasbullah Consultant -
3 Rotating Equipment Specialist Member
Yaakub Vysus
Consultant -
4 Hyffny Athraz Electrical Specialist Member
Vysus
Consultant -
5 Mohammad Faris Instrumentation Specialist Member
Vysus
Sabreena M Consultant -
7 Process Safety Specialist Member
Aslam Vysus
Consultant -
8 Saiful Rizal Pipeline Specialist Member
Vysus
Consultant -
9 Nazarul Kahar HSE Specialist Member
Vysus
Consultant -
10 Rashid Kadir Structural Specialist Member
Vysus
Member/
11 Habib Sanusi Regulatory - OSRMS PTTEP
Observer
Member/ PTTEP
13 Jailanee Othman Regulatory - OSRMS
Observer
Member/ PTTEP
15 Jascelina Bujang Regulatory - OSRMS
Observer
9.0 APPENDIX
• Appendix 1: OSR Document List
• Appendix 2: Audit Checklist
• Appendix 3: Findings Template
1. Governance Documentation
2. Discipline Specific Documentation
2.1 Lifting Equipment
2.5 Structural
2.6 Pipeline
1. Governance Documentation
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
11 Asset Register
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
18 RCM Manual/analysis/study
Asset/Equipment Reliability Report & KPIs for
19 each facilities
21 PM/CM Reporting/KPIs
31 Maintenance Log
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
4 Crane Datasheet
11 MOC Records
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Repair/Overhaul Report for Major Electrical
1
Equipment
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
2.5. Structural
5 SIM Procedure
16 Pushover Analysis
17 Fatigue Analysis
21 Helideck Certificates
23 Latest Metocean
25 Seismic Analysis
2.6. Pipeline
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
6 MOC Records
Refer Anomaly
12 Anomaly Master list
register
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Not
Yes No
No. Description Available Remarks
(Y) (N)
(NA)
Ref Doc : Integrated Operational Asset Integrity Assurance (IOAIA) Manual 2019
1. Audit Findings
2. Audit Observations