1
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
msg-hse-eni spa-eng-all S-C-r01
29 July 2015
The English text is a translation from the Italian. For any conflict or discrepancies between the two texts the Italian document shall prevail.
Management System Guideline
HSE
Process Safety
Management System
Annex S-C
2
HSE
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
1. Introduction .................................................................................................. 4
1.1 Purpose of this document ........................................................................... 4
1.2 Area of application .................................................................................... 4
1.3 Procedure for implementation ..................................................................... 5
2. Process description ........................................................................................ 6
2.1 General .................................................................................................... 6
2.1.1 Process Safety .................................................................................... 6
2.1.2 Process Safety management ................................................................. 8
2.1.3 Process Safety management procedure .................................................. 8
2.2 Process risk ............................................................................................ 10
2.2.1 Activities with a higher process risk ..................................................... 10
2.2.2 Activities with a lower process risk ....................................................... 10
2.2.3 Criteria for classifying activities with a higher / lower process risk ........... 11
2.2.4 Causes of process accidents ................................................................ 11
2.2.5 References ........................................................................................ 13
2.3 Process Safety Management ..................................................................... 14
3. The process safety management system......................................................... 15
3.1 Commitment to Process Safety ......................................................... 17
3.1.1 Process Safety culture ....................................................................... 17
3.1.2 Compliance with standards ................................................................. 20
3.1.3 Process Safety Competency ............................................................... 23
3.1.4 Involvement of employees and contractors ........................................... 30
3.1.5 Consideration of Stakeholders' Needs .................................................. 31
3.2 Hazard identification and risk assessment .......................................... 32
Contents
3
HSE
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
3.2.1 Process knowledge ............................................................................ 32
3.2.2 Hazard Identification, Risk Assessment and Identification of Critical
Elements for Safety and the Environment ............................................. 34
3.3 Risk management ........................................................................... 37
3.3.1 “Operating Manuals” .......................................................................... 37
3.3.2 Work practices and permits ................................................................ 39
3.3.3. Inspections and Maintenance .............................................................. 40
3.3.4 Contractor management .................................................................. 43
3.3.5 Training ........................................................................................... 45
3.3.6 Management of Change ..................................................................... 46
3.3.7 Pre-Start Up Safety Review ................................................................ 48
3.3.8 Operation ......................................................................................... 50
3.3.9 Emergency management .................................................................... 52
3.4 Accident management and management system verification .................. 54
3.4.1 Investigation .................................................................................... 54
3.4.2 Indicators......................................................................................... 56
3.4.3 Auditing ........................................................................................... 57
3.4.4 Management Review.......................................................................... 60
4. Definitions .................................................................................................. 61
Contents
4
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
1. INTRODUCTION
1.1 Purpose of this document
1.2 Area of application
This document outlines the Process Safety Management System and supplements the
HSE MSG document.
The Process Safety Management System applies to company activities with a
significant HSE risk according to consolidated clustering procedures adopted for
fixed facilities. Transport activities via pipelines are included, while transport by
road, rail, sea and other water courses are excluded.
The Process Safety Management System is applied to the three levels of the HSE
Management System, unless otherwise indicated. This document identifies all
aspects of the Process Safety Management System, concerning both intrinsic
characteristics of an operational nature which are only applicable to operating sites,
and more general aspects applicable to all company scenarios.
1
5
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
1.3 Procedure for implementation
This document has immediate effect for eni spa.
Subsidiaries will ensure that this attachment is promptly implemented and in any
case no later than 31 December 2015, according to procedures described in the
MSG “Regulatory System”.
Subsidiaries with shares listed on a regulated market will receive this document and
implement it, adapting it, where necessary, to their own specific aspects, in line
with their level of management autonomy and taking account of the interests of
minority shareholders.
6
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
2. PROCESS DESCRIPTION
2.1 General
As Process Safety, in line with the Chemical Centre for Process Safety (CCPS) and
Oil & Gas Producers (OGP):
comprises a set of technical and managerial competencies aimed at
preventing major accidents, and in particular explosions, fire and
damage associated with the release of energy or hazardous
substances such as chemical and oil products;
and
Process Safety management means the proactive identification,
assessment, prevention and mitigation of releases of matter and
energy that could result from process or equipment malfunctions, or
inadequate administrative controls;
the purpose of the Process Safety Management System is the
prevention and mitigation of risks of a major accident by adopting
high management and technical standards, such as best practices in
the design, operation, maintenance and disposal of assets.
2.1.1 Process Safety
Process Safety is the result of the correct management of assets during their life cycle.
It therefore implies:
design, in accordance with the applicable technical and safety standards, using
adequate methodologies and competencies for hazard identification during the
design stage and for defining preventive and mitigation measures consistent
with the tolerable risk defined by legislation and company standards;
2
7
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
development, in accordance with design requirements and with the
requirements identified during risk analyses conducted in the course of the
design stage;
operation, in accordance with adequate, updated technical and operating
documents, with the knowledge of technological processes and associated
risks and with the use of adequate human and managerial resources;
maintenance, in accordance with the best technical and managerial practices in
terms of technology, maintenance and inspections;
the management of plant modifications, technological and organisational
changes according to a correct hazard identification and risk management;
the decommissioning of assets that are no longer used, in accordance with
adequate procedures for managing residual risk.
This document identifies the essential elements of Process Safety in the
managerial, organisational and technical methodologies used by different areas
(design, drilling, construction, technology, production, inspections, maintenance),
in each stage of the assets life cycle and their management within a specific
system. The purpose of grouping these elements and operating principles and
application procedures that together constitute Process Safety is to promote
uniform management procedures, in compliance with specific technical and
organisational aspects of each Business Unit.
Process Safety is also related to Operating Reliability, as the elements at the base
of operating reliability affect the existence of process safety. Operating Reliability
is one of the elements that results in Operating Excellence being achieved. Thus,
Operating Excellence can only be achieved if there is a high level of Process
Safety.
8
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
2.1.2 Process Safety management
The aim of Process Safety management is to prevent and mitigate situations that
create a risk for people, the environment, surrounding communities and assets,
due to loss of containment of hazardous substances.
While establishing its foundations on a correct asset management, the Process
Safety management connects:
the management of HSE (Health, Safety, Environment) risks, aimed
at ensuring workers' health and safety and protecting the
environment and surrounding communities, which is regulated by
specific internal guidelines (HSE MSG)
with
the management1 of assets through adequate management practices,
organisational and technical methodologies typical of different areas
(design, drilling, construction, technology, production, inspections,
maintenance, …) in each stage of its life cycle, which are regulated by
specific guidelines (for example MSG for Project Development,
Operations, Maintenance, Procurement, etc.);
Process Safety management therefore involves significant interaction with Asset
Integrity management, which is defined in the MSG Operations as an activity with
the purpose of maintaining an optimal production level, while safeguarding people,
the environment and the company's reputation during the entire life cycle.
2.1.3 Process Safety management procedure
In order to convert the elements of the Process Safety management system into
operating tools, the HSE functions, in consideration of the cross functional nature
of the Process Safety elements, promote the integration between the various
company functions on such elements, ensuring the coordination of the related
1 Also with reference to the management of assets for which eni has HSE obligations.
9
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
activities. At the level of Business Units and subsidiaries/operating sites, this
management process is based on arrangements specific to each Business Unit.
In Business Units without a centralised technical/operating structure, the HSE
coordinating role is exercised towards the subsidiary operating functions, which
may be delegated to convert the Process Safety elements into operating tools.
This task shall be recorded in a specific document.
Steering, coordination and control activities cannot be delegated and their
responsibility remains with the Business Units.
10
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
2.2 Process risk
Process risks are related to accidents with a low probability of occurrence
compared to other risks related to general industrial activities like occupational
risks, but with the potential to cause serious damage to people, the environment,
company assets and company image.
Typical process risks include but are not limited to:
fire;
explosions;
the release of substances hazardous to people and/or to the environment;
in addition to events typical of the upstream sector like:
well blow outs;
Process risks are part of the so-called major risks, covered by legislation at a
European level (Seveso Directive and Offshore Safety Directive). Legislation on the
same subject, but with a different structure, is enacted in many OECD countries,
including the US OSHA Process Safety Management, and in various non-OECD
countries.
2.2.1 Activities with a higher process risk
For the purposes of this document, the Oil & Gas / Refining / Petrochemical / Gas
Transport and Distribution sectors are considered as having a greater process risk,
because of their activities, therefore this document applies to these sectors in full.
2.2.2 Activities with a lower process risk
In the Power Generation sector, a Process Safety management system is not
currently required on a regulatory level. In this document, such system is
proposed as an internal standard, in line with the European Power Generation
sector's gradual adoption of process safety standards, typical of the Oil & Gas and
Petrochemical industries.
11
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
As risk situations arising from loss of primary containment of hazardous
substances are more limited in the Power Generation sector compared to the Oil &
Gas / Refining / Petrochemical / Gas Transport and Distribution sectors, for the
purposes of this document, Power Generation activities are considered as having a
lower process risk. The Power Generation activities fall within the remit of the
present document, nevertheless it is accepted that the implementation of what
stated in it is based on criteria and procedures adequate for the sector and so less
stringent than those of the other sectors mentioned. This also applies to Power
Generation facilities on sites where Oil & Gas / Refining / Petrochemical / Gas
Transport and Distribution activities are carried out.
2.2.3 Criteria for classifying activities with a higher / lower process
risk
In this document, the elements of the Process Safety management system have to
be applied in the same way to activities with a higher process risk and to activities
with a lower process risk, unless otherwise indicated.
2.2.4 Causes of process accidents
The causes of process accidents can be grouped into the following categories:
technological defects
human error
inadequacies of the management system
external circumstances and natural phenomena
The most significant cause of process accidents in all sectors stems from a
vulnerability/absence of/failure of application of the relevant management system,
which cover a range of factors, such as:
the functional decay of equipment or instruments due to inappropriate
maintenance, inadequate inspections;
12
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
the inadequate process risk assessment during operation and/or changes;
deviations from process parameters due to instrumentation problems or a
deliberate operating change not sufficiently analysed at a technological and
safety level
work procedures absent, incomplete or out of date;
technical documents absent, incomplete or out of date;
inadequate training of personnel;
insufficient process knowledge;
inadequate supervision of operations;
Also Technological defects and human errors can be prevented and mitigated on
condition that a system of knowledge of design standards, of process technologies,
of risk assessment and management as well as a system of personnel training and
awareness are established and implemented.
The purpose of a Process Safety Management System that includes these aspects
is to indicate the reference principles and implementation ways to ensure that
these inadequacies or vulnerabilities are addressed.
13
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
2.2.5 References
Centre for Chemical Process Safety – Guidelines for risk based process safety
Energy Institute (EI) – High level framework for process safety management
Occupational Safety & Health Administration (OSHA) - Process Safety
Management
Oil & Gas Producers (OGP) – Safety reports
14
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
2.3 Process Safety Management
Effective management of Process Safety shall, in line with the different types of
hazards and risks related to operating activities:
be promoted and supported by a consistent Process Safety culture at all levels
of the organisation;
be based on precise knowledge of processes and the identification of hazards
and risks related to the operations of the specific production units;
duly consider the importance of human, technical and financial resources
necessary to guarantee the safety of operations;
be integrated with the company's other Management Systems.
15
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3. THE PROCESS SAFETY MANAGEMENT SYSTEM
The Process Safety Management System consists of 20 elements:
Commitment to Process Safety
Process Safety Culture
Compliance with Standards
Process Safety Competency
Involvement of Employees and Contractors
Consideration of Stakeholders' Needs
Hazard Identification and Risk Assessment
Process Knowledge
Hazard Identification, Risk Assessment and Identification of Critical Elements
for Safety and Environment
Risk management
“Operating Manuals”
Work Practices and Permits
Inspections and Maintenance
Contractor Management
Training
Management of Change
Pre-Start-up Safety Review
Operations
Emergency Management
16
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Accident Management and Management System Verification
Accident Investigation
Performance Indicators
Auditing
Management Review
17
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.1 Commitment to Process Safety
3.1.1 Process Safety culture
Description of the element
Process Safety Culture, which is part of the Safety Culture, i.e. a set of values and
behaviours that determine the approach to Safety, is a fundamental element for
the correct development, application and improvement of the Process Safety
Management System.
Process Safety culture is based on:
commitment starting from the highest levels of the organisation;
leadership at a managerial, technical and supervisory level;
which are all part of a management system that ensures compliance with laws,
regulations and best practices.
The values and behaviours inherent in the Process Safety Culture ensure, through
their diffusion and sharing within the organisation, that each person understands
the importance of the applicable rules and regulations, is aware of the
responsibilities associated with their activities and to what extent a deviation from
the applicable rules and regulations is inconsistent with the Process Safety values.
The Process Safety Culture not only provides a mind-set to understand that strict
compliance with the applicable rules and regulations is the right thing to do, but
also makes people more aware of how to react when such a set of directions does
not cover a particular contingent situation.
Description of the management process
Employers shall ensure that all personnel are aware of their own responsibilities in
Process Safety.
Support for Process Safety shall be visible, active and consistent at all levels of the
organisation.
18
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Process Safety shall have resources and standing adequate and comparable to
other sectors such as production, quality, etc.
Process Safety objectives shall be defined at different levels of the organisation, as
in HSE MSG, and their achievement shall be reviewed at regular intervals.
An incentive system shall be established to reward righteous behaviour and
positive results achieved, as well as a zero tolerance system shall have to be
enforced against deliberate violations of rules and regulations concerning Process
Safety.
Objectives, development plans and results with regard to Process Safety shall be
documented.
Training and the development of knowledge and expertise in all technical and
operational functions shall be highly valued.
The prompt observation and reporting of abnormal conditions, also through the
systematic analysis of near misses, shall be encouraged, in order to readily
identify warnings that may predict safety problems.
A willingness to deal not only with reported problems but also with suggestions for
modifications and improvements of procedural and operational aspects shall be
evident.
Information on Process Safety issues shall be promptly exchanged and their direct
notification through the organisational structure shall be ensured.
A communication channel for the prompt reporting by employees of Process Safety
issues shall be provided.
Increasing awareness and understanding of hazardous conditions shall be
developed in order to achieve a continual improvement of Process Safety
performance.
The tendency to underestimate risks shall be addressed.
The importance of addressing any abnormal situation shall be highlighted.
19
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
A disciplinary system, with clear criteria defining unacceptable behaviour and able
to distinguish between genuine mistakes and deliberate violations, shall be
developed and enforced.
The prompt reporting and resolution of Process Safety problems shall be
considered a priority.
Process Safety issues, however reported, shall be dealt with corrective actions that
are timely and documented.
All aspects that may impact Process Safety performance shall be directly
monitored on a frequent basis.
20
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.1.2 Compliance with standards
Description of the element
Establishing and keeping a system of standards helps maintain the safety of
assets, the application of Process Safety best practices and the compliance with
applicable laws.
A standards management system identifies, acquires, evaluates, disseminates and
provides access to standards, regulations and laws. Regulations and laws may be
local, national or international.
Description of the management process
Employers shall identify all mandatory laws and technical standards. Relative
deadlines shall be monitored.
Regulations and standards that may be adopted on a voluntary basis are identified
by the Business Units based on the particular process technology, product, facility
concerned and by eni for more crosscutting topics activities.
Activities concerning compliance with standards shall be documented with a
sufficient level of detail to guarantee that all Process Safety obligations have been
met and that all significant sources of potential changes to these obligations are
monitored.
A list of all applicable standards shall be made available to each Business Unit.
Responsibility for filing, updates and access shall be regulated.
Compliance with regulatory standards and laws shall be ensured by personnel
whose professional background is adequate based on company criteria. In
particular, training and refresher courses on applicable standards shall be planned
at regular intervals. Specific training shall be arranged on the impact of new laws,
regulations and technical standards as well as information sessions for personnel
concerned.
21
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Business Units shall carry out periodic control and upkeep activities to ensure
adequate updates to legal, regulatory and technical standards and guarantee the
efficiency of the standards system.
The adoption of a standards system shall include:
the definition, by the Business Units, of legal, regulatory and technical
standards applicable to each type of equipment;
the identification of a “standard ownership” function in each Business Unit,
with defined roles and responsibilities;
a control programme for each site listing all equipment and instruments
covered by laws, national technical regulations, international standards or best
practices;
Each Subsidiary/operating site shall have / be familiar with:
applicable legislative provisions relative to equipment and instruments installed
at the site (applicable national laws, EU directives and regulations), or parts of
said;
national technical regulations and international standards applicable to
equipment and instruments installed at a site or a part of said;
Changes concerning legislative provisions, technical regulations or best practices
shall be notified to other Business Unit functions. The relative impact shall be
evaluated and discussed between the Business Unit concerned functions.
The establishment of or changes to regulations and standards shall be promptly
evaluated with regard to possible effects and impacts on activities carried out by
the Business Unit.
Documentation inherent to on compliance with regulations and standards kept at
each Business Unit shall be kept regularly updated.
Each Business Unit shall maintain evidence of the update, implementation and
control activities related to compliance with standards.
22
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Participation in courses, seminars and meetings held by national/international
industry or professional associations shall be coordinated by the Business Unit and
HSE function in order to disseminate knowledge as effectively as possible.
The auditing system shall include compliance with standards, at each level. The
status of legislative and technical compliance shall be periodically reported to
management.
For this element a diversified approach based on the classification criteria between
activities of higher / lower process risk can be applied.
23
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.1.3 Process Safety Competency
Description of the element
Establishing and maintaining a competency based system consists in:
updating and continually improving knowledge and competencies;
guaranteeing that all persons involved have correct information;
supplying knowledge consistently and systematically.
Process Safety knowledge and competencies are developed and maintained by
being acquired and diffused within the organisation, through a structured training
system and the effective dissemination of new knowledge to appropriate functions
within the organisation.
Competency in Process Safety, which in turn is based on the technical competency
of the individual elements constituting Process Safety, and in particular the
technology knowledge, the knowledge of process, materials and equipment used,
shall be verified to ensure that required competencies are maintained and
developed within the organisation and that competencies present in certain
functions (typically technology, maintenance and maintenance engineering) match
the needs of those functions that benefit directly, i.e. that operate production
assets.
Description of the management process
Business Units shall define specific objectives for Process Safety competency, in
line with company criteria. These objectives shall guarantee that competency in
the various elements of Process Safety is maintained and developed.
The elements for which specific competency is the cornerstone of Process Safety
are:
24
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
knowledge of the specific company process (unit operations and unit
processes, temperature and pressure conditions, properties and hazardous
nature of processed substances, chemical reactions kinetics and
thermodynamics, effect of physical and chemical deviations on the process,
controls to prevent deviations, preventive and mitigation measures in case of
deviations, analytical controls of products and intermediates, effect of external
variables such as power failures, instrument failures or lack of utility supplies,
transient operating conditions);
design and operating requirements of process equipment and instrumentation;
materials knowledge in order to define the suitability of materials used to
process characteristics;
inspections and technical verifications to carry out for guaranteeing the reliable
operation of instrumentation and equipment;
hazard identification and risk analysis, risk-consequence scenarios evaluation;
knowledge of and ability to manage major accident scenarios;
assignment of responsibility for maintaining and developing Process Safety
competencies; this responsibility shall be assigned to the manager of each
function that will be in charge of maintaining and developing each element of
Process Safety competency.
Competency in Process Safety elements shall be part of an approach to operations
that does not focus on these skills only for their positive impact on Process Safety,
i.e. on preventing and mitigating process accidents, but also for achieving
operating excellence, through reliable process and plant operation, with positive
results in output level, product quality and cost optimisation. With this approach,
the absence of process accidents is no more than a consequent positive fall-out.
As part of the strategic plan to stay in one business or develop new businesses, a
plan shall be established at Business Unit level indicating for each relevant
function the necessary ways and means (methods and resources) to maintain and
acquire the specific competencies related to Process Safety.
25
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The identification of specialist functions with process knowledge ownership
responsibility for each production process at a Business Unit level and of specialist
reference functions for materials science and corrosion, is a significant prerequisite
of a Profess Safety competencies system. The function with responsibility for
process knowledge ownership shall have an important role supporting the project
manager in projects relative to the specific process it has competency for. Process
knowledge ownership not only refers to specific production processes, but also to
specific types of knowledge or areas of know how.
When a specific process knowledge ownership function cannot be assigned,
because of the crosscutting nature of the competencies required, specific
communication and information exchange platforms shall be established, such as
Communities of Practice (CoPs). CoPs may be used to consolidate competencies
and Business Units and the HSE function are responsible for establishing them.
An essential role of the process knowledge ownership function is on one hand to
ensure that an official record of process documents (process manual) is kept,
including therefore information inherent to Process Safety and on the other end to
inform the relevant functions of changes or updates of the documents. This role
may be delegated to Employers, through the technical functions under their
responsibility, provided that the process knowledge ownership function establishes
an adequate verification system to control that the arrangement works properly.
These documents include:
a copy of reference technical reports and of the relevant technical process
documentation (flow diagrams, material balances, P&IDs, electrical diagrams,
interlock sheets, equipment and instrument data sheets, plant operating
manuals);
a copy of the reference documents related to the changes made to the process
or plant over time;
a copy of the reference documents related to the accidents occurred to the
company process or to other companies similar processes worldwide;
26
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The process knowledge ownership function can be located either on an operating
site or at the relative Business Unit Headquarters. Regardless of the geographical
location, the function shall always be able to ensure directly or indirectly through
controls, in case the responsibility is delegated to Employers, the availability in a
precise location and the updating of the process documents.
Process documents shall be accessible to all personnel concerned, along with all
applicable updated standards related to equipment part of the specific production
process.
Process documents shall be managed as part of a quality assurance system, with a
set of rules that requires their periodic revision and circulation to functions
concerned. The process documents updating shall be responsibility of the site
Technical functions or of the Business Unit, with the process knowledge ownership
function being responsible for ensuring through controls that the system works
properly. The updating of Process documents, not consisting solely of pure
revisions of the existing documents but of new guidelines or standards shall have
to be accompanied by specific training courses for technical support personnel.
Updates due to new technological knowledge or experience from "lessons learned"
after accidents or near misses in processes/at company plants or in other
scenarios worldwide shall be disseminated not only to relevant site and Business
Unit technical functions (technology, maintenance, etc.), but also extensively to
the management of Business Units. The process knowledge ownership function
shall ensure that process documents are properly revised, taking account of
updates notified by the relevant technical functions for each element, of
information and experience from company process/plant operation and from
external sources concerning processes/plants of other operators worldwide. The
process knowledge ownership function shall guarantee the technological
monitoring of business competitors in the widest possible sense (including Process
Safety aspects), the participation in technical or industrial associations where the
27
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
process technology aspect is considerable and the monitoring of national and
international technical literature of the specific process.
The process knowledge ownership function shall ensure a frequent contact with
operations at individual sites, specifically during industrial testing or process/plant
modifications.
In order to ensure that required technical competencies by site and Business Unit
technical functions managers, as well as of specialist positions, are maintained, a
register of the knowledge skills required by each specific professional area to
which refer for training programmes should be established.
The development and maintenance of a Process Safety competencies system
requires holding periodic seminars for the main technical focal points of a
particular production process at one or more company sites, in order to exchange
information and discuss projects, modifications, accidents operating experience.
All seminar proceedings shall be gathered in a document which shall be circulated
to functions concerned. The organization of such seminars and the management of
the associated information shall be the responsibility of the Business Unit function
in charge of process knowledge ownership.
The participation of technical personnel in associations should be promoted, in
order to:
share best practices with other companies;
develop technical documents in common with other companies;
keep up to date with the development status in other companies of relevant
issues;
In view of the specific nature of a particular process knowledge and of the fact
that not all relevant information lies within the company, participation in
professional associations gathering market suppliers of specific product categories,
shall be promoted. With it goes the selection of appropriate figures, acting as
company focal points in these associations and disseminating to the relevant
28
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
company functions the information acquired or exchanged in such conferences.
The figures and positions from individual Business Units and eni central functions
participating in technical and industrial associations shall be included in a list that
is periodically updated at a Business Unit and HSE function level. All participations
in technical or industrial associations shall be the subject of periodic reporting by
each participant to his/her function manager, or alternatively, published on an
intranet collaboration area.
As with other activities, an annual review of the organisation, results and
adequacy of the competencies system is necessary both at Business Unit and at
eni level. Topics subjected to review include:
role effectiveness of the process knowledge ownership functions;
availability and updating of process documents;
consistency between personnel turnover, competencies required and training
needs identified on the basis of the knowledge skills register of the specific
professional area;
The HSE function shall organise at least with a yearly frequency at eni level
meetings aimed at sharing lessons learned from accidents or near misses occurred
at the various Business Units. Each Business Unit shall collect all necessary
information and share it in the course of the meeting. The eni HSE function shall
officialise the information and circulate them to all relevant Business Units
functions. Eni HSE function shall ensure the gathering of information on process
accidents outside eni and on their associated lessons learned, share and discuss
them with the Business Units concerned. Wherever necessary, the HSE function
shall have the responsibility of promoting the relative improvement actions.
For this element a diversified approach based on the classification criteria between
activities of higher / lower process risk can be applied.
29
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Criteria and methods for managing competencies are defined in the MSG “Human
Resources” and in the eni documents relative to professional areas.
30
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.1.4 Involvement of employees and contractors
Description of the element
All resources shall be committed to obtaining a high standard of Process Safety.
Each person, regardless of their role in the organisation, shall be committed to
ensuring and consolidating the safety of company operations.
Description of the management process
Employers shall identify and put in place initiatives to inform all resources and
make them aware of their role in Process Safety and encourage proactive
contributions. This activity shall target employees and contractors alike,
considering that the latter may have a considerable impact on safety performance
at a site without this being offset by a sense of belonging to the company which
instead is felt by employees.
Adequate monitoring of involvement and participation of everyone helps to keep
this system effective. Likewise, the enactment of proposals and the provision of a
rational explanation in case they are turned down, encourages the individual’s
contributions.
Both eni and Business Units shall identify uniform ways to encourage active
participation in maintaining safety performance, using appropriate systems that
recognise contributions made. This means that, besides meetings specifically
required by some national laws, such as meetings with workers' safety
representatives, strategies must be pursued from involving all employees and
contractors in case of specific deviations from safe behaviour and of accidents
(safety stand down) and in case of information on plant modifications, till creating
a structured system, such as the safety meetings at various levels required by
safety management systems (like Dupont).
31
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.1.5 Consideration of Stakeholders' Needs
Description of the element
Maintaining good relations with stakeholders and engaging with them on matters
of operations’ safety shall be based on established criteria and methods, within the
framework of the company a regulatory system, taking into account applicable
laws, practices and the specific nature of the geographic location.
Description of the management process
Stakeholder involvement shall not be limited to complying with particular national
laws (consultations concerning environmental, health or social impact assessments
or information on the risks of the production site supplied to authorities and
communities), but shall also include actions such as:
informing Authorities on occasion of events occurring on site, that by their
effects may alarm the surrounding community;
engaging with authorities/organisations that manage emergencies (for
example: Fire Brigade and Civil Protection Service) organising common
emergency drills and holding shared seminars on technical and regulatory
matters;
holding periodic, systematic meetings with local communities;
The methodology and criteria for engaging with stakeholders are defined in the
MSG “Sustainability stakeholders engagement and community relations”
32
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.2 Hazard identification and risk assessment
3.2.1 Process knowledge
Description of the element
Process knowledge, i.e. all information consisting of technical documents, technical
specifications, equipment drawings, material balances, PFDs, P&IDs, layout
drawings, calculations, safety data sheets, etc. are fundamental for Process
Safety.
This knowledge needs to be detailed and comprehensive in order to adequately
identify hazards and analyse risks.
Description of the management process
The technical documentation relative to each process shall be kept in a Process
Manual that includes all documents relevant to process knowledge. This Manual
shall be periodically revised and updated to take into account changes made to the
process / plant and technological developments.
Besides information in the Process Manual, Employers shall make available all data
on the chemical/physical characteristics of substances handled and processed
(including information on their reactivity and their incompatibility with other
substances), as well as on their toxicological properties, together with the
information on their correct use from a health and safety point of view, like those
included in safety data sheets.
The Business Units shall identify a process knowledge ownership function within
their organisation, in order to guarantee the correct management of the above
information, i.e. to maintain updated, accurate know-how of the processes, to
take into account changes in know-how and to provide a technical reference for
any process or plant modification, as well as know-how support for the
development of new projects. Process knowledge ownership duties are defined in
the chapter “Competencies”.
33
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The Business Units shall standardise the technical documentation of processes and
assets as far as possible. This means that "operating manuals" shall have a unified
structure. Symbols used in P&IDs, electrical diagrams, etc., although produced by
different entities, shall be unique and calculation models shall be standardized.
Information forming the basis of Process Knowledge shall be checked regularly to
ensure it is adequate, correct and updated.
Business Units shall ensure that Process Knowledge information is checked
regularly, so that the Process Safety Management System is correctly maintained
during the life cycle of the process / plant, in order to carry out new studies, if
necessary.
Since Process Knowledge information is critical, it shall be managed as part of a
quality assurance system.
As process knowledge information is critical for company know how, it shall be
adequately archived and kept.
For this element a diversified approach based on the classification criteria between
activities of higher / lower process risk can be applied.
The methodologies and criteria and for knowledge management activities -re
defined in the MSG “Human Resources”.
34
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.2.2 Hazard Identification, Risk Assessment and
Identification of Critical Elements for Safety and the Environment
Description of the element
The purpose of process risk management, i.e. risk assessment and the
development of strategies to manage it, is to maintain the integrity of assets,
protect public safety and people's health, as well as the environment.
Hazard identification and risk assessment covers the entire lifetime of the process;
its purpose is to guarantee that risks are controlled at all times and are within the
acceptability limits established by the company.
Risk assessment identifies Safety Critical Elements and Environmental Critical
Elements, and its purpose is to offset the occurrence of a hazard (prevention), or
reduce its consequences (protection), so as to protect assets, public safety and
people's health, as well as the environment.
These Critical Elements are identified according to principles of the EU Seveso
Directive or to definitions in use in each country. In the absence of clear
legislation, the following definitions are used:
A Safety Critical Element (SCE) is defined as: “any system, component or part of
an installation designed to prevent or limit the effects of a loss of containment that
directly, or due to a domino effect, may result in a major accident, the failure of
which would cause or contribute substantially to a major accident “
An Environmental Critical Element (ECE) is defined in the same way as an SCE,
but also includes devices, that although not part of the installation, are used to
contain spills of liquid pollutants both onshore and offshore, and to monitor, collect
and store/dispose of such spills”.
Description of the management process
Each Business Unit shall adequately regulate the hazard identification and risk
assessment process for each stage of the process / plant life cycle, in order to take
35
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
into account the specific aspects of process risks and any consolidated practices.
The Business Units shall also provide specific guidelines on the ways and
frequencies for updating this process.
Employers shall carry out hazard identification and risk assessment in accordance
with indications from their Business Unit. They shall guarantee that all activities
are adequately monitored, controlled and tracked in order to systematically
provide data for the planning and review activities required by the continual
improvement cycle.
The process to systematically identify hazards makes it possible to assess risk, i.e.
the comparison of the identified risk with its acceptability criterion, in order to
decide on reduction measures, if any.
Each Business Unit shall adequately regulate the process to identify SCEs and
ECEs, based on the risk assessment, for each stage of the process / plant life
cycle, and shall define the type of performance expected for each element (for
example the SIL, or availability on demand). Likewise, each Business Unit shall
provide specific guidelines on the ways and frequency for updating the
identification process and its frequency, also on the basis of
(temporary/permanent) process changes/modifications.
Employers shall guarantee that SCEs and ECEs are kept in good working order and
are included in preventive maintenance processes with the highest level of
priority. Each Business Unit shall verify that the number, adequacy and
functionality of these Elements is periodically audited in Process Safety Audits. The
results of these audits shall be tracked to systematically provide data for planning
and review activities required by the continual improvement cycle.
Process risks and risks from natural events
Process risk management is applied to the entire asset life cycle, including
decommissioning, and also covers risks from natural events (Na Tech event:
Natural – Technological event).
36
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The risks connected with natural events are specific in terms of location and
prevention and mitigation methodologies. These risks shall be managed adopting a
specific approach identified by each Business Unit.
For this element a diversified approach based on the classification criteria between
activities of higher / lower process risk can be applied.
The general criteria for hazard identification and risk assessment are defined in
the HSE MSG Attachment “HSE risk management”.
37
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3 Risk management
3.3.1 “Operating Manuals”
Description of the element
“Operating manuals” provide documentary support for handling assets and
carrying out related operations. They provide detailed instructions on how to carry
out activities and the necessary information for the personnel in charge to
properly manage activities and all plant operating conditions: from start-up to
normal operation to any type of shut-down.
Description of the management process
The criteria for identifying operations that require an "operating manual" to be
produced, the methods for preparing these manuals and their standard contents
shall be defined by each Business Unit in a document that also identifies the
responsibilities for preparing, updating and circulating them.
Employers shall ensure that “operating manuals" are prepared according to criteria
defined by their Business Unit. They shall also guarantee that only the latest
versions of manuals are used, amending them to promptly include any changes
(to plants, technologies, organisation, regulations, etc.), and correct any errors.
They shall periodically check that the manuals reflect actual plant conditions and
operating practices. "Operating manuals" shall be made available to all operating
personnel and used as training material.
"Operating manuals" for plant operation (plant operating manuals) shall provide
detailed instructions to operate the plant they refer to. They shall therefore include
information on process, equipment instrumentation, control and protection
systems, considering also the possible deviations and their consequences. For
process parameters with established operating limits, it shall be described how to
bring the process to normal operating conditions.
38
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Additional "operating manuals" shall be prepared for interconnected assets
whether managed by the same operating personnel or by other operating
structures, giving the necessary instructions for an integrated operation.
"Operating manuals" shall also be prepared for activities related to plant
operation which require specific details (such as sampling, draining, field controls,
data recording, HSE specific precautions to adopt). These do not replace training
for operating personnel, but supplement the acquired knowledge with instructions
for specific activities.
39
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.2 Work practices and permits
Description of the element
Activities at the plant, other than plant operation, may have to be carried out as
required in specific documents and/or managed using specific forms.
A work permit is the main tool for managing activities carried out by personnel
operating outside their normal work area or working on non-routine activities.
Description of the management process
Each Business Unit shall define and regulate the activities it considers necessary
for internal uniformity of practices (e.g. the identification of plant fluids, usage of
flexible hoses, vehicle access to plant areas, practices for PSV calibration and
testing, etc.), through specific documents to ensure safe execution. Additional
administrative tools for managing activities other than plant operation may be
identified by each Business Unit based on the specific nature of its activities.
Employers shall ensure that specific documents are implemented and relative
forms produced, in line with the Business Unit document. They shall also identify
and regulate all activities which - in their opinion - in order to be carried out safely
require a specific procedure, and for which consolidated practices and/or training
by designated personnel are not considered sufficient.
Activities carried out by resources from other internal organisational structures
and above all activities carried out by employees interacting with third parties
need to be strictly regulated. For this purpose, administrative tools suitable for
identifying and separating roles and responsibilities of all persons involved shall be
defined, developed and adopted.
The essential requirements for correctly developing and managing work permits
are defined in the HSE MSG Attachment “Guidelines for managing work permits”.
40
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.3. Inspections and Maintenance
Description of the element
Equipment, instruments, and more generally, any item used at a plant, shall be
designed, built, installed and maintained in good working order for the entire life
cycle, with the aim of minimising possible accidents due to their failure or
malfunction. To this end, an Inspections and Maintenance programme shall be
defined and implemented, with the identification of items of equipment, of criteria
and frequencies of inspections, the specification of documented maintenance
practices.
Particular attention shall be dedicated to inspection and maintenance of Safety and
Environmental Critical Elements defined according to criteria in section on Hazard
Identification, Risk Assessment and Identification of Critical Elements for Safety
and the Environment.
Description of the management process
Each Employer shall ensure that a programme of controls and inspections is
developed for all equipment and instruments covered by laws, national technical
regulations, international standards or best practices and is in line with any
additional requirements of the relative Business Unit.2. Subject to this
requirement, in the scope of the programme, priority shall be given to
equipment/piping containing hazardous substances, safety systems and items that
have been assessed as critical for safety. Other Items shall be identified on the
basis of considerations relative to the risk of their failure / malfunction.
The criteria for identifying Safety Instrumented Systems (SIS) and for determining
their required Safety Integrity Levels (SIL) shall be defined by the Business Units.
2 The purpose of this programme is to prevent the spill of any process fluid, including, if present and pending replacement as required by law, substances that are
harmful for the ozone layer.
41
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
In addition to what required by legislation, national technical regulations and
international standards, the Business Units, on the basis of internal process
accidents and near miss findings, of the application of Risk Based Inspection
techniques, of inspections/maintenance results as well as of reports of accidents
occurred elsewhere, shall define an additional list of controls, tests and inspections
of equipment and instrumentation, or parts of them, installed at sites, to be
submitted to sites for their planning and implementation.
Maintenance shall focus on the prevention of possible failures, in particular of most
critical plant components. The best suitable level of preventive maintenance
depends on technical feasibility and economic cost, as well as of the safety critical
level of plant items.
The conditions of equipment and instrumentation at each site shall be monitored
on the basis both of general documented practices and of the items’ specific
nature determined by manufacturers' recommendations, history, criticality,
previous monitoring results, etc.
Employers, in order to develop documented internal inspection and maintenance
practices, shall ensure adequate information/training of maintenance personnel on
maintenance standards (criteria and techniques) that reflect current level of
experience in the industry. Maintaining competency at individual sites and at a
Business Unit level is essential.
On each site inspection and tests results shall be made readily available and
promptly analysed, so that any necessary maintenance is immediately carried out.
In case of unexpected results, the information shall be used to identify potentially
similar conditions for other equipment and/or site.
Restoring a proper item functionality shall be carried out in the shortest possible
time. In case this is not feasible and a temporary repair has to be carried out, it
shall be carefully evaluated in relation to the risk involved according to the
Management of Change procedure.
42
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Proper Record keeping and storage of audit information is essential and shall be
guaranteed.
Since often maintenance involves repairs, servicing or reconstruction, rather than
replacement, care shall be taken to ensure the suitability of parts and materials
used.
A quality control system shall be implemented to guarantee the suitability of
materials used and of the handling and installation process.
The criteria and methods for Inspection and Maintenance activities are defined in
the MSG “Maintenance”.
43
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.4 Contractor management
Description of the element
In order to safeguard the safety of operations and the company’s reputation, the
use of contractors to carry out works requires an adequate selection process based
on an evaluation of competencies, ability and certifications.
At the same time, a high level of control by the Client is necessary in order to
ensure the Contractors' compliance with rules regulating their activities and in
general, the monitoring of their presence on site.
Description of the management process
The use of contractors for performing on site activities calls for the definition of
selection criteria that take in due consideration the HSE performance. These
criteria shall be applied as well to all subcontractors.
Principles, criteria and methods for the vendor qualification process in relation to
the evaluation of HSE requirements shall have to be defined. In particular, all
activities that require an analysis and evaluation of HSE aspects shall be detailed,
indicating methods, roles and responsibilities. In relation to HSE aspects, the
vendor qualification process shall have to define in detail the vendor registration
and qualification stages.
The selection of Contractors for performing on site activities has to be consistent
with the MSG Procurement.
The HSE aspects to be considered are defined in a specific document regulating
the management of HSE aspects in the vendor qualification process.
Contractor activities shall be monitored on an ongoing basis, for control and
performance evaluation purposes.
In order to ensure that coordination and supervision are regular, effective and
enforced during the entire execution of the contracted (and subcontracted) works,
services and supplies, Employers shall plan and implement activities such as HSE
44
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
meetings and inspections and shall take appropriate actions such as the resolution
of HSE nonconformities. For each action / activity, the principles to adopt for a
correct implementation shall have to be defined.
All concerned parties shall be involved in the definition of timing and methods for
coordination and supervision activities, on the basis of their specific competencies
and responsibilities.
Methods for monitoring third parties activities are defined in a specific document
that regulates the Control of Third Parties.
45
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.5 Training
Description of the element
All personnel, including contractors, shall have full knowledge and be made fully
aware of hazards related to the performed activities. Operating personnel shall
also be specifically and adequately trained to carry out their activities in
compliance with HSE requirements.
Specific training shall be provided to resources that operate in contexts like
technology, maintenance, engineering, inspections, etc. that require a high level of
competency and technical knowledge.
Description of the management process
Employers shall ensure that all personnel, including contractors, are given a basic
set of information including a description of the processes and hazards of the
workplace and are informed of the site's reference documents on (process) safety.
Adequate information shall also be given to site visitors.
Operating personnel shall receive Process Safety training that is specific and
adequate for the activities they carry out. They shall also be trained to carry out
their assigned activities in compliance with Process Safety requirements.
Training standards and procedures shall be defined by Business Units and
implemented by Employers on sites.
Business Units shall have and maintain a coordinating role on the training of those
positions where competencies and knowledge are of fundamental importance.
Employers shall ensure on a regular basis a verification of the effectiveness of
training imparted to personnel in terms of acquisition, assimilation, maintenance
and application of knowledge. Each Business Unit shall define the scope and
procedures for these verifications, as well as indicators that may appropriately
alert of a decline in performance.
Training criteria and methods are defined in the MSG “Human Resources”.
46
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.6 Management of Change
Description of the element
The Management of Change has the purpose of ensuring that any change (in
technical documentation, in organisation, in plant assets, in engineering materials,
in raw materials, in process instrumentation and control etc.) does not introduce
unidentified hazards or increases unintentionally any existing risk.
Risks arising from any type of change, i.e. a change other than a mere
replacement in kind, shall be systematically identified, evaluated and managed
before the change takes place. These activities shall also be carried out for
changes which are limited in time and for which, after a certain period, pristine
conditions are restored.
Description of the management process
Each Business Unit shall define criteria for identifying changes falling under
"Management of Change” and shall define roles and responsibilities of the
positions involved in the entire process. The Business Units shall also work out
specific documents on Management of Change, indicating procedures to follow
during the evaluation and implementation of these changes.
Employers shall adopt the criteria and change management procedures defined by
their Business Unit, ensuring that the circulation of information on changes
reaches all persons concerned.
The realization of rapid changes dictated by exceptional circumstances shall have
to be possible. In this case, a procedure for ensuring minimum control
requirements and an adequate level of authorisation shall have to be defined. The
change shall then be evaluated using the normal procedure, in the shortest
possible time.
All measures identified as necessary to manage risks arising from a change, shall
be operational when the change is becoming effective.
47
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
After the consequences of a proposed change have been evaluated, authorisation
for its implementation shall have to be given at an adequate hierarchical level.
In case of a temporary change, the evaluation process shall also define its
maximum allowed duration. The Management of Change procedure shall also
establish ways to check that original conditions have been restored in the
prescribed timing.
48
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.7 Pre-Start Up Safety Review
Description of the element
PSSR (Pre-start up safety review) comprises all activities aimed at bringing a plant
into operation. Its purpose is to check that the accomplished project work
conforms to the project (or modification) design and all measures to eliminate /
reduce risks previously identified have been implemented.
Description of the management process
Each Business Unit shall define the general procedures for the handover of a
project/modification to the client at the end of construction, and in particular the
criteria regulating the PSSR, with the aim of achieving normal operation, while
keeping at all times the plant and process in safe conditions. Similar procedures
shall have to be defined in order to re-start the plant after a shut-down for
maintenance or modifications.
In case of modifications, the "Management of Change" process shall have to be
carried out previously.
Employers shall develop specific site operating instructions for PSSR, on the basis
of Business Units guidelines and procedures.
In case of first start-up or of start up after plant modifications, the necessary
verifications shall have to be carried out by a multidisciplinary team using the
required process documents (manuals, drawings, diagrams, MSDS, etc.). It is
always advisable, and necessary in the case of new equipment, to carry out an
hazard analysis (HazOp or other method with same purpose).
Any recommendations / requirements (punch list) deriving from this process shall
have to be complied with before start-up. Should these recommendations /
requirements evaluated as non-binding for start-up, a compliance date shall be
defined in any case.
49
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
All activities having an impact on the plant safe operation, with the inclusion of
personnel training, shall be completed before start-up.
The criteria and methods for the handover of a project/modification to the client at
the end of construction are defined in the MSG “Development of Industrial Projects
in the energy and environment sectors" and in the MSG “Operations”.
50
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.8 Operation
Description of the element
The safe performance of all site activities, in particular of operations, is strictly
related to overall site reliability. To this end, a standard approach to operations
management has to be defined.
Description of the management process
The control of operations is essential to guarantee their integrity and continuity.
Employers shall guarantee that operating personnel have an accurate knowledge
of plant operating conditions at any particular moment in time. This means
regularly checking the conditions of equipment and instrumentation both in the
field and in the control room. As equipment and instrumentation may show signs
of malfunction that tends to increase over time, it is important to identify, report
and correct any anomaly as soon as it occurs. It is therefore appropriate that
operating personnel carries out this kind of checks systematically and is trained to
understand hazards caused by malfunctioning.
In presence of critical operating parameters, whereby safety critical manual
actions are performed by personnel when certain thresholds are reached, a
specific personnel training shall have to be foreseen.
Effective communication between people is essential; efficient procedures shall
therefore be identified and adopted for exchanging information between groups of
people operating in the same function (field personnel vs. control room personnel,
shift handovers, interaction among different operating structures, etc.) and
between people operating in different functions (operating personnel vs.
maintenance personnel, plant operators vs. logistics operators, etc.).
Business Units shall define specific rules for employees, contractors and visitors,
and relative vehicles and work equipment, to access plant areas and control
rooms.
51
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
Work areas shall be kept clean and tidy at all times. Areas assigned to third
parties shall be adequately identified; checks shall have to be made to ensure that
they are kept in line with site standard conditions.
52
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.3.9 Emergency management
Description of the element
The consequences of an accident may be decreased considerably if the
organisation of emergency management has been properly established in terms of
means available and operational readiness.
Identifying scenarios that an emergency team may face is essential in order to
conduct periodic drills to check and improve emergency preparedness. It is equally
important to ensure that all personnel at a site, including non-operating personnel,
contractors and visitors, know how to behave in an emergency.
Description of the management process
Employers, in compliance with requirements of existing regulations in the country
where they operate, shall prepare emergency plans. To this end, they define roles,
responsibilities and measures to be taken to control risk in emergency situations.
Emergency operations personnel and all those charged for the actuation of
emergency measures shall have specific competencies and a level of training that
enables them to adequately carry out the emergency management duties formally
assigned to them. To this end it is necessary to carry out verifications aimed at
ensuring the specific requisites of selected personnel, their traceability and the
formal acceptance of the duties assigned to them.
Employers shall ensure emergency management through:
the identification and evaluation of likely accident scenarios and effects;
the emergency operations management;
the planning of emergency drills and their follow- up.
All emergency equipment shall always be available and regularly checked to
ensure its functionality. In particular, checks on consumable materials and
materials with expiry dates shall have to be carefully managed.
53
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The effectiveness of emergency management shall be carefully evaluated by the
Employer as inadequate performance in the course of an accident may have major
consequences.
Employers shall ensure that all people that might be involved in an emergency
(non-operating personnel, contractors, visitors), are trained and informed of how
to behave. To this end, drills shall be conducted at regular intervals to check that
the emergency plan has actually been understood and people know how to
implement it. Simulations in conditions that are as realistic as possible and
observation by competent external resources make drills more significant.
All recommendations resulting from emergency drill observations shall be
immediately converted into corrective actions to be completed in the shortest
possible time, under Employer’s responsibility. These recommendations and, more
generally, all observations from emergency drills shall be shared within the
Business Units in order to maximise their value.
The general criteria for emergency management are defined in the HSE MSG
Attachment “Emergency plans and crisis management”.
54
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.4 Accident management and management system
verification
3.4.1 Investigation
Description of the element
Investigation is the process which identifies the causes of an accident and the
actions to be taken take in order to avoid the recurrence of similar events; its
purpose is to learn from experience.
Accidents investigation results and relative corrective actions shall be recorded in
a specific database.
Description of the management process
Al accidents shall be investigated. The investigation shall be carried out at the site
where the accident has occurred, under the responsibility of the Employer. The
investigation shall be started as soon as possible after the event, in order to
gather fresh, direct information.
Standards methodologies shall be used and selected resources systematically
involved, in order to guarantee a necessary uniformity of investigations. The
investigation team requires adequate technical knowledge; if not available within
the team, this knowledge shall be provided by external resources. The
involvement of resources external to the subsidiary/operating site and/or Business
Unit and/or eni shall be related to the significance of the event.
For each identified cause, associated recommendations shall be defined and
implemented in an action programme.
Investigation results shall be circulated to all those involved with the kind of
activities which the event under examination refer to.
The Business Units shall always evaluate the opportunity of sharing investigation
results with sites under their responsibility. The HSE function shall identify
55
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
investigations results to discuss in the periodic meetings on lessons learned, held
with the Business Units.
The HSE MSG Attachment “Investigation (Accidents and near misses)” defines the
criteria for classifying the actual and potential severity of an event, the methods
for carrying out the investigation, the profile of resources used and follow-up
actions.
Accidents, investigation results and corrective actions shall be recorded using the
Accidents Database (INDACO).
Procedures for using INDACO are defined in the HSE Professional Operating
Instruction "Procedures for managing accidents using the Accidents Database
System (INDACO)”.
56
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.4.2 Indicators
Description of the element
A system of indicators makes it possible to monitor the effectiveness of the
Process Safety Management system, to identify criticalities and areas for
improvement and therefore to govern the continual improvement process.
Description of the management process
Indicators shall be defined for each element of the Process Safety Management
System.
The HSE function, in agreement with the HSE function of Business Units, identifies
the (minimum) set of indicators necessary to monitor Process Safety performance.
Employers shall ensure that indicators are collected and monitored and notified to
the HSE function of their Business Unit. The Business Unit ensures that the eni
HSE function is then informed.
The procedures for identifying, collecting and reporting Process Safety
management system performance indicators are defined in the HSE MSG
Attachment “Planning, monitoring and reporting of HSE indicators” and in the
"HSE Professional Operating Instruction“.
57
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.4.3 Auditing
Description of the element
The auditing of the Process Safety Management System consists in the systematic
verification of all system elements, in terms of their adequacy and actual
implementation. This auditing process, which is conducted at regular intervals, is
essential for achieving Process Safety objectives, as it pro-actively identifies areas
for improvement in the management system structure and performance.
Additional audits
Besides systematically verifying the 20 elements of the Process Safety
Management System, additional audits, useful to to evaluate site Process Safety,
are conducted, such as:
operational safety audits, with a general aim or with a specific one on
matter of fire and explosion risk;
insurance surveys aimed at verifying financial exposure to industrial risk;
audits aimed at verifying the integrity of preventive and mitigation barriers
against process incidents (BART methodology);
technical audits aimed at verifying asset integrity and evaluating the
reliability (Safety Integrity Level, SIL) of safety instrumented systems
(SIS ).
The Auditing element of the Process Safety Management System, as well as other
complementary audits, is an important tool for assessing and managing process
risk, with all its legal, financial and reputational connotations both for directly
controlled activities and for business partnership activities.
In order to ensure an acceptable level of risk exposure for eni, the Business Units
HSE functions, besides applying to activities directly managed and controlled the
principles and tools outlined in this document:
58
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
shall ensure with similar tools and procedures the correct assessment and
management of process risk in business partnership activities directly
managed or jointly managed with other operators;
shall identify together with the operators of companies where they are only
financial partners tools and procedures for assessing and managing process
risk, in order to safeguard the direct or indirect responsibilities of eni.
Description of the management process
The auditing of the Process Safety Management System is carried out at three
levels: at subsidiary/operating site, at Business Units and at eni level.
The first level audits are conducted annually. In the course of them, the Employer
regularly verifies the correct enforcement of site or Business Unit
procedures/instructions on matter of process safety elements. It generally
coincides with normal controls of activities carried out at the site, it takes place
throughout the entire year and is based on protocols defined by the individual
Business Units.
The second level audits are conducted every three years. The purpose of these
audits is to verify the application of the Process Safety Management System at
sites. It is within the capacity of the Business Unit HSE function to determine a
higher frequency of these audits in consideration of the particular level of risk
associated with the subsidiary / operating site audited, such as:
perceived operational risk
level of safety culture at the subsidiary/operating site
previous audit results
accident history or particular regulations in force at the subsidiary /
operating.
59
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
The audit team may consist of Business Units internal resources or of third party
resources with Business Unit participation. These audits shall verify all relevant
documentation as well as actual implementation of what required; therefore plant
field verifications and meetings with operating personnel shall be part of the audit.
The third level audits are conducted every three years. The purpose of these
audits is to verify the application of the Process Safety Management System by
the Business Units, in order to assist the review process. The associated
methodologies are defined by the HSE function, in agreement with the Business
Unit HSE functions.
Complementary audits
Complementary audits are defined and conducted according to protocols and
frequencies defined by the Business Unit HSE functions or by eni structures
(depending on the type of audit).
General criteria for conducting Process Safety Management System audits are
defined in the HSE MSG Attachment "Criteria and methodologies for HSE audits".
60
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
3.4.4 Management Review
Description of the element
The Management Review element evaluates whether the management system is
working as required and is producing expected results, with the intended
effectiveness: this review is therefore a check-up of the "health" of the
management system.
Description of the management process
The Management Review process shall provide evidence that management system
requirements have been complied with and that evidence of previous reviews and
other audit activities have been adequately addressed. It shall also provide
elements for continual improvement of the management system.
The review shall be conducted annually during normal HSE review activities. The
HSE functions reviews Process Safety in global terms every two years (alternating
between eni international activities and eni Italian activities).
61
msg-hse-eni spa-eng-all S-C-r01
This document is the property of eni spa. All rights reserved.
HS
E
Annex S-C - Process Safety Management System
4. DEFINITIONS
This chapter gives definitions of those documents or functions not otherwise
referred to in other documents of regulations.
Process manual
Document explaining how a process operates, which includes extensive
information on the process.
Process knowledge ownership
A function with an assigned responsibility for maintaining process knowledge.
Top Related