Description of Gap or Gaps Use additional rows for each Potential Action.

Transcription

1 API P API P 1173 equirement Has Top Management established and documented the goals and objectives for the PSMS? Has Management documented a process for addressing regulatory and legistlative requirements? List or statement of the PSMS goals. List of measureable objectives for the Corporate communications. Corporate HSE Manual. A procedure that describes how regulatory and legislative requirements are identified, applicability to the organization is determined, how the requirements are implemented within the organization. Annual letter to employees from the organization's president restating the HSE goals of no accidents, injuries or releases to the environment. Sustainability eport contained specific safety initiatives. rganization has a person monitoring regulatory activity and uses bulletins from APL, API and XXX Consultants for legislative activities. (/N) N No documented process or procedure. No process for translating requirements into internal procedures and instructions No process for monitoring compliance to applicable regulatory requirements. Description of Potential Action(s) to Close s. Prepare a procedure that documents the process of monitoring regulatory and legislative activity for environmental, personal safety, occupational health, security, pipeline, transportation and other applicable regulatory issues. Prepare a procedure to convert applicable legislative and regulatory requirements into procedures and instructions. The procedure will include: 1. Process to determine applicability to the organization. 2. Process to determine regulatory requirements. 3. Process to identify regulatory tasks. 4. Process to communicate and assign regulatory tasks. 5. Process to prepare instructions or procedures for completing the tasks. Prepare a procedure for monitoring compliance to regulatory requirements including: 1. Documentation of completion of regulatory requirements. 2. eview of completion documentation. 3. Process for addressing identified regulatory noncompliance. equired (), Has Management documented a process for budgeting and resource planning for the PSMS? Has Top Management established and documented high-level performance Has Top Management identified and documented the executive(s) accountable for implementation and continuous improvement? Has Top Management identified and documented the managers responsible for each element of the PSMS? A procedure that describes how within the budgeting and resource planning processes the goals and objectives for the PSMS are taken into account and addressed. List of measureable high-level performance measures. Corporate communications. List of executives with identification of their accountabilities for implementation and continuous improvement of the Identification of the procedure owners in individual procedures to be used in the List of managers, by PSMS element, responsible for that element. Identification of the procedure owners in individual procedures to be used in the ole descriptions. rganizational chart has all the managers listed by name and title. Department description and function documents describe what the department does. Activities described in each PSMS element is covered in at least one department description, but specific responsibility for the PSMS activity is not assigned. ole descriptions. Some of the PSMS elements are included in multiple department descriptions. Could not determine if the identified departments were responsible for all or part of the PSMS element. perations, Accounting, HSE and Emergency esponse all include communications in their department descriptions. isk management is included in the description documentation for Integrity Management, Emergency esponse and Corporate Finance departments. PSMS elements did not have assigned managers. Update the department description and function documentation to be more specific and include the specific PSMS element or portion of the element the department will be addressing. Identify specific managers for each PSMS element/sub-element, document the responsibility, communicate the responsibility.

2 API P API P 1173 equirement Has Top Management communicated its commitment to the PSMS to internal and external stakeholders? Communications documents - letters, s, minutes of meetings, newspaper articles. (/N) Description of Potential Action(s) to Close s. equired (), Has Management ensured clear connection between objective and day-to-day work activities? Assessment of the objectives, traceable to procedures and finally to the person(s) responsible for doing the work required by the procedure. f the 5 safety objectives, 4 had detailed action plans. 'Demonstrate Genuine Care and Concern' did not have an action plan. The action plan for 'Make Safety Personal' addressed only personal safety and did not address process safety (risk). Demonstrate Genuine Care and Concern' did not have an action plan to connect to day-to-day activities. Develop an action plan. eview the last Safety Culture assessment and develop an action plan for each measure with a score of less than 70% 'Make Safety Personal' action plan did not include how process safety or risk management will be linked to day-to-day activities. Update the 'Make Safety Personal' action plan to include process safety. The update will include: 1. Updating the process description portions of the operating procedures with the risks identified in the process hazards review that require operating personnel to be knowledgeable of the risk and the appropriate operating procedure to address that risk. 2. Broaden the 'Safety Suggestion' program to include process safety/risk issues. 3. Include a topic in a future training standdown about how everyone is involved in process safety and managing risks. Include an interactive discussion for employees to identify how they are involved. Use this as feed back to update the action plan. eview the safety culture questions/measures and determine if process safety and risk management is adequately covered Has Management established and documented performance measure for each element of the PSMS? List of performance measures for each PSMS element. KPI Dashboards. See Has Management identified and documented personnel responsible for PSMS elements? A list of personnel responsible for each PSMS element. ole descriptions. rganizational charts. 5.5 Are accountabilities, responsibilities and authorities for developing, implementing and improving the PSMS defined, communicated and documented? Table listing accountabilities, responsibilities, authorities. ole descriptions. Evidence (letter or , signoff on role description) of communication to the identified persons. rganizational chart. Department description and function documents. Each PSMS element is covered in at least one department description. ole descriptions. Accountabilities were not documented. Development and implementation was not identified in department descriptions. Improving is implied but not stated in the department descriptions. Accountabilities were not documented. Authorities were not identified, documented and communicated. esponsibilities were not clearly identified. For each PSMS element/sub-element identify who is accountable for developing, implementing and improving that element/subelement. For each PSMS element/sub-element identify who are the authorities (subject matter experts) for developing, implementing and improving specific topics in the element/sub-element, document the authorities and communicate the assignment of authority. For each PSMS element/sub-element identify who is responsible for the development, implementation and improving the specific element/sub-element, document the responsibility and communicate the responsibility.

3 API P 1173 API P 1173 equirement (/N) Development and implementation the PSMS was not documented and improving the PSMS is implied but not documented in the department descriptions. Description of Potential Action(s) to Close s. Update the PSMS implementation plan to include the list of responsible persons and authorities for development and implementing the PSMS elements/sub-elements and where to permanently document the accountabilities, responsibilities and authorities for improving the PSMS and how these roles will be communicated in the future. equired (), 6.1 Is there a process and a plan for communication and engagement with internal and external stakeholders? Communication plan or procedure. egulatory-required communication plans. Public Awareness Plan Investor relations communication procedure. Emergency response procedures - communication flowchart and telephone numbers. Media Department - esponding to the news organizations requests for information and interviews, monitoring the news for references to the organization and how to generate and make press releases. Sustainability eport. Web site. Documentation of communication plans is all for one-way communication except for emergency situations and media request. Web site has contact names and telephone numbers for specific topics. No overall plan for communications with external stakeholders. Update the department descriptions to include improving the Update the various communication plans to include how to engage external stakeholders in communications beyond responding to questions and educational communication. Develop and document a plan for how communication with external stakeholders will be managed. The plan will include: 1. Identification of the various communication methods. 2. What type of information will be communicated. 3. Expectations for receiving questions/comments and for responding. 4. Forums or other opportunities to engage (conversation) with external stakeholders. No overall plan for communications with internal stakeholders. Develop and document a plan for how communication with internal stakeholders will be managed. The plan will include: 1. Identification of the various communication methods. 2. What type of information will be communicated. 3. Expectations for receiving questions/comments and for responding. 4. Forums or other opportunities to engage (conversation) with internal stakeholders. 6.2 Are there documented processes to communicate the importance of meeting requirements of the PSMS to the organization? Communication plan or procedure. egulatory-required communication plans. Meetings, such as Safety Meeting, State of the rganization Presentations. 6.3 and a plan for two-way communication with external stakeholders? Communication plan or procedure. Community Advisory Panels Is there a list of external stakeholders? Does the communication process document how highlevel view of company safety operations, current focus of risk management efforts and List of external stakeholders. Mailout lists with property owners, municipality officials, businesses along or near the pipeline assets. Communication plan or procedure. Citizen Advisory Panel presentations. Community presentations.

4 API P 1173 API P 1173 equirement 7.1 Is there a procedure for performing risk management? isk Management procedure. Process hazards analysis procedure. Pipeline pressure test procedure. isk-based pressure test alternative procedure. Gulf of Mexico pipeline navigational risk and inspection procedure. Navigable water crossing risk evaluation. (/N) Procedures do not cover all pipeline assets. Procedures do not identify the threats to the pipelines except the topic threat. Description of Potential Action(s) to Close s. Identify the other pipeline assets and develop procedures for each asset. equired (), Develop a risk management procedure for all pipeline assets. H John Doe 9/1/2016 Not started. Identify the risk assessment method to be included in the risk management procedure(s). [What-if, Checklist, HAZP, FMEA, Develop a list of threats for each type of pipeline asset. Update the procedures for assessing all the threats. H Jane Doe 6/1/2016 In progress, on target for due date. Develop risk management procedures for other pipeline assets that includes the lists of threats. 7.1 Are pipeline safety risks analyzed and are decisions made on how to manage the risks through preventative controls, monitoring and mitigation measures? isk Management procedure. Process hazard analysis procedure. isk Matrix or isk anking eport. For each risk, identification of the preventative controls, monitoring activities and/or mitigation measures. 7.2 Is there an inventory of pipeline data that is required to define safe operating conditions? Pipeline material and operating data. Pipeline maps and identification of the environments which the pipeline transverses Is there an inventory of pipeline data that is required to analyze the risk? Are risks to pipeline safety identified? Pipeline operational safety information such as pressure relief studies, facility siting studies, pump/compressor information, engineering information (design codes, materials of construction, isk piping Matrix and instrument or isk anking diagrams) eport. Threat list Did the risk assessment consider the likelihood and severity of threats using an industry-recognized risk management tool? Is the risk assessment reviewed annually and updated as warranted? Are the results of the risk assessment reviewed with top management at least annually? Documentation within the isk Management procedure of the risk management tool(s) to be used. Documentation within the isk Management procedure for the requirement to review annually and update as warranted. evision history to the isk Matrix or isk anking eport. Documentation from a risk assessment review meeting. Documentation of a meeting with Top Management to review the results of the risk assessment. Management eview documentation (agenda, minutes, decisions, actions)

5 API P API P 1173 equirement Do procedures document that an employee may stop work in cases where the employee believes following the procedure will cause an Are unsafe there condition? procedures for the initital start-up and do they include safe operating limits? normal operations and do they include safe operating limits? Statement in the PSMS documentation. Statement in procedures. Procedure Deviation procedure. Initial operations instructions. Identification of the safe operating limits. Engineering project documentation. perations procedures. Safe operating limits in procedure. Alarm and Shutdown documentation. Control logic. perating procedures did not contain safe operating limits. perating procedures contained set points for operating conditions. Instrumentation documentation contained alarm and shutdown setting. (/N) perating procedures did not contain safe operating limits. Safe operating limits can be inferred from alarm and shutdown setting identified in the instrumentation documentation. Description of Potential Action(s) to Close s. Update the operating procedures with the safe operating limits. Update the operating procedures with instructions for actions to take as process parameters approach safe operating limits. equired (), perators do not have access to instrumentation documentation for alarm and shutdown settings. Provide a controlled copy of instrumentation documentation for access by operators. No documentation of what is considered safe operating limits. Determine and document the safe operating limits and update alarms and shutdowns as appropriate. temporary operations, as needed, and do they include safe operating limits? perations procedures. Safe operating limits in procedure. Alarm and Shutdown documentation. emergency situations, including emergency shutdowns, and do they include safe operating limits? normal shutdown and do they include safe operating limits? perations procedures. Safe operating limits in procedures. perational (control system) triggers for emergency shutdowns. Triggers for perator initiated emergency shutdowns. perations procedures. Safe operating limits in procedure. Alarm and Shutdown documentation. startup or restoration of operations following maintenance or an outage and do they include safe operating limits? perations procedures. Safe operating limits in procedure. Alarm and Shutdown documentation.

6 API P API P 1173 equirement Are there procedures identifying the design specifications, quality testing procedures and construction procedures for manufacturing and construction of pipeline assets and do these conducting maintenance activities in a safe manner? Are there testing and inspection procedures for pipeline safety-related equipment and do they identify the testing criteria to be used, what is and is not an Are there safe work procedures to assure the safe conduct of operating, maintenance and emergency response activities, such as lockou/tagout, confined space Are operating procedures reviewed at least annually? Engineering project procedures. Fabrication and installation procedures/instructions. Construction procedures/instructions. Field manufacturing procedures. Construction records. Quality control or testing records. Maintenance procedures. Identification of maintenance hazards in Job Safety Analysis and the associated procedure with the safeguards to be Testing and inspection procedures. Industry standards for testing - Pass/Fail criteria, Traceability of the calibration of testing equipment to recognized standards. Safe work procedures. egulatory-required safe work procedures. Safe work procedures identified in risk assessments. evision history page for procedudres indicating review dates as well as changes. Signed procedure certification page. (/N) Description of Potential Action(s) to Close s. equired (), Is there a Management of Change procedure that addresses changes in technology, equipment, Does the Management of Change procedure require documentation of the reason for the change, the authority for approving the change, analysis of the implications of the change and Is there a procedure for managing the activities outsourced? Does the contractor management procedure include communicating the requirements of the PSMS, training and orientation on safety policies, evaluating the contractor's safety performance, communicating risks at the work site, Is there a procedure for investigating incidents and near misses? Management of Change procedure. Management of Change procedure. Management of Change documentation. Pre-Startup Safety eview procedure and documentation. Contractor Management procedure. Bridging documents (describing the HSE working relationship between the organization and the contractor). Contractor Management procedure. Bridging documents (describing the HSE working relationship between the organization and the contractor). eviews of contractor's safety performance. Incident investigation procedure. Includes investigating near misses. Incident reporting procedure. Near miss reporting procedure.

7 API P API P 1173 equirement Does the investigation procedure require the identification of the cause(s), identification of contributing factors, identification of lessons learned and identification of recommendations or actions to prevent recurrence? Is there a procedure to document the findings, the lessons learned and the recommendations (actions) and track the recommendations to completion? Incident investigation procedure. Near miss investigation procedure. Incident investigation procedure. Action tracking system. Criteria for when an action is considered completed. Action completion verification process. Incident eporting and Investigation procedure, Section 3 - Investigations (/N) N Description of Potential Action(s) to Close s. equired (), Is there a procedure to communicate the cause(s), contributing factors, recommendations or actions Lessons learned procedure. Incident investigation procedure. Safety meeting topic library. to prevent recurrence and Incident investigation procedure or for periodically evaluating lessons learned procedure. past incident investigations for Database of incidents and near misses new lessons learned and with causes identified. effectiveness of lessons learned? No procedure identified to evaluate trends in incidents. No process for periodic evaluating past incident investigations for new lessons learned and for effectiveness of lessons learned. Develop a procedure for evaluating past incidents. The procedure will include: 1. Frequency for conducting the evaluations. 2. Guidance for selecting the range of incidents for evaluation. 3. Evaluation techniques that may be used. 4. Documentation of the evaluation. 5. Documentation of new actions and use of the action tracking system. 9.4 for evaluating external events to identify opportunities to learnings for improving pipeline safety? Lessons learned procedure. Safety meeting topic library Are audits used to examine conformity of the PSMS to the requirements of API P 1173? planning, conducting and documenting audits and evaluations? Audit records. Audit procedure. Audit schedule. Evaluation schedule. Audit procedure. Audit schedule does not include PSMS topics. Audit procedure does not include PSMS in the scope of the procedure. Update the Audit procedure to include PSMS in the scope of the procedure and how the frequency of the audit topics will be determined. Update the audit schedule to include PSMS topics No procedure for conducting evaluations required by Develop a procedure for conducting the required PSMS evaluations. The procedure will include: 1. Evaluation topics. 2. Evaluation frequency. 3. Qualifications of evaluators. 4. Evaluation techniques. 5. Information needed to conduct the evaluation. 6. Evaluation documentation requirements. 7. Communication requirements of the results of the evaluation Are evaluations used to assess the effectiveness of the risk management performance? isk management evaluation report. Process hazard assessments.

8 API P API P 1173 equirement Does the risk management assessment cover Sections 6 through 13 of API P 1173? Are there documented processes for evaluating the safety culture of the organization? to evaluate the maturity of the PSMS? Do the findings of audits and evaluations have defined response times? Are the findings of audits and evaluations reported in the management review? Are records of internal audits maintained? for reporting and providing feedback to employees and contractors to report new and emerging risks? isk management evaluation report. Management eview meeting minutes. Safety culture evaluation procedure. Safety culture assessment results. Culture assessment contractor's procedures/methodologies. PSMS maturity evaluation procedure. Management eview minutes. Audit procedure. Audit reports. Evaluation reports. Action tracking system. Audit procedure. Management review agenda and Audit records. Communication plan or procedure. Documentation of the methods that new risks can be reported. Safety suggestion program. (/N) Description of Potential Action(s) to Close s. equired (), 10.4 Is there a procedure to identify key performance indicators? Key Performance Indicator procedure. Procedure should be how to identify the KPIs and how they are to be measured and linkage to the KPI Dashboard on HSE department web site. KPI for onstream reliability. No procedure for the identification of key performance indicators. No leading KPIs. Develop a procedure for the identification of leading and lagging key performance indicators. Identify leading KPIs Are key performance indicators identifed to measure the effectiveness of risk management and the effectiveness and adequacy of Is there a procedure for the identification, collection and analysis of data for the key performance indicators? Key Performance Indicator list. Key Peformance Indicator procedure. Processes used for personnel safety indicators/statistics Is there a procedure for conducting management review? Management eview procedure. No management review procedure. Annual HSE and perational management performance reviews. No management review procedure. Develop a management review procedure. Develop procedures for the HSE management review and for the perational management review to include the requirements of In the management review is the PSMS and safety performance reviewed to determined which Are recommendations for improvement from the management review integrated into the next for Management to evaluate risk management for Management to Management eview procedure. Management review agenda and minutes. Annual safety performance reviews. Management review agenda and minutes. Management review action item list. evision history of PSMS procedures. Management review procedure. Management review procedure.

9 API P API P 1173 equirement periodically evaluate new Does Top Management review and approve the output of the management reviews at least annually? Are there emergency preparedness and response procedures for responding effectively to a pipeline Engineering project reviews. Management review procedure. Management review agenda and minutes. Top Management's signature on mintues Emergency esponse plans and procedures. (/N) Description of Potential Action(s) to Close s. equired (), 12 Do the emergency preparedness and response procedures contain the regulatory-required elements; identification of the potential types of emergencies; safety, health and envirionmental protection processes; training and drills, including with external agencies; lessons learned and improvement process and periodic review and update of the plans? Emergency esponse plans and procedures. List of potential emergencies. Drill records for potential emergencies. Drill records that include external agencies involved in the drill. Drill and incident critiques. Intergrated esponse Plans. SPCCs. Emergency esponse Plans. Emergency perations Center Procedures. Fire esponse Procedures. Process Hazards Analysis eports. Process Hazards Analysis reports contained emergency scenarios that had not been included in emergency preparedness and response procedures. Emergency preparedness and response procedures were identified as risk mitigation measures. Drills were not conducted with external agencies at all locations. Drill critiques were not documented at all locations eview the Process Hazards Analysis reports for emergency scenarios and include them in emergency response plans and procedures. Brainstorm a list of potential emergency scenarios. Identify the emergency scenarios that used emergency response and preparedness plans as mitigations and include them in the emergency drill rotation. Update emergency response plans and preparedness procedures to include drills with external agencies and the frequency for conducting those drills. Update emergency response plans and preparedness procedures to include a requirement to document drill critiques. 13 Does the pipeline operator have a procedure for assuring personnel have the appropriate level of competence for their roles in the PSMS? perator Qualification Program. Training procedure (identifies the Q program as part of the procedure). Competency determination for non-q roles (example auditors and management). perator Qualification Program. peration staff competency requirements spreadsheets. No procedure for assuring personnel have the appropriate level of competence for roles in the All PSMS roles did not have level of competency determinations. Develop a PSMS competence procedure. It may include references to other existing competency programs. Include level of competency determinations for all roles in the PSMS competency procedure that are not already documented under other competency programs. Develop an action plan to document the compentency requirements, evaluate incumbents against those requirements, develop individual action plans to satisfy any gaps in competency Has the pipeline operator defined and documented the need and provided the training for the development and implementation of the Is there a document or procedure management procedure that identifies the documents needed to support the PSMS, how they will be reviewed, by whom, how often and how they will be changed if necessary. It will also include how to identify Is there a records management procedure that identifies the records that are necessary to demonstrate conformance to the PSMS, where and for how long the Training procedure. esults of an assessment for training needs. Plan for providing the training. Document Management procedure. List of documents that need to comply with this procedure. ecord retention manual or procedure. ecords Management procedure. ecords etention Manual. Corporate ecords etention Manual Corporate ecords etention Manual does not specify responsibility and storage locations for locally generated PSMS records. Update the Corporate ecords etention Manual with the locally generated PSMS records. Develop local ecords etention Manuals for locally generated PSMS records.

10 API P API P 1173 equirement where and for how long the records will be maintained, how the records will be protected from damage or destruction, who is responsible for the generation of the record, record quality requirements and at the appropriate time how the record will be (/N) Description of Potential Action(s) to Close s. Update the Corporate ecords etention Manual with requirements for the local management of PSMS records. The requirements will include: 1. List of locally generated PSMS records. 2. Identification of record owner and storage location. 3. etention life. 4. Disposal requirements. equired (),