AI-PS Element Guide

Element 2: Compliance with Standards

AI-PS Element Background Asset Integrity Process Safety (AI-PS) is the means of ensuring that
the people, systems, processes and resources, which deliver
AI-PS in PDO integrity, are in place, in use and fit for purpose throughout the
whole lifecycle of the asset. The aim is to be able to confidently
Assuring the safety of our people, our assets, the environment and state that ‘our assets are safe and we know it’.
the company’s reputation is a core value of PDO and providing
assurance that we are managing our major process safety risks is a Asset Integrity Process Safety Management is a complex area of
critical aspect of our corporate governance. Asset Integrity Process expertise covering a wide range of components, all of which are
Safety (AI-PS) describes the way we manage our assets so that the essential to ensuring systems, processes and equipment perform as
processGU-XXX-02
Doc. Reference: risk is As Low As Reasonably Practicable (ALARP). required. There are a number of Elements which make up the Asset
Integrity Process Safety management system.
Version: Issue 1.0
What it is
Date: 10 August 2011
Doc. Owner: Head of Technical Safety Engineering (MSE4)
Element Owner: EOIM Manager (UEPI)
Structure of AI-PS Assurance in PDO Element 15: Conduct of Operations
Element 16: Emergency Management
PDO has a three-tiered approach to AI-PS assurance:
Element 17: Incident Management
Level 1: Includes audits conducted on behalf of PDO's Internal Audit Element 18: Measurements and Metrics
Committee (IAC) as part of the Integrated Audit Plan. This includes
Element 19: Audit and Verification of Level 2 Process
independent audits carried out by external bodies, such as Shell.
Element 20: Management Review and Continuous Improvement
Level 2: Includes audits carried out on behalf of Asset Managers as
part of their own Asset level assurance processes. Element 2: Compliance with Standards
Level 3: Includes task verification and assurance activities that
supplement the formal audit process.  Background to Element

There are 20 elements in total within the PDO AI-PS Management The Compliance to Standards Element aims to ensure there is a
System as follows: suitable system in place that can be used to identify, develop,
acquire, evaluate, disseminate, and provide access to applicable
Elements list: standards, codes, regulations, and laws that affect process safety.
Aims and Objectives of Element
Element 1: Process Safety Culture
Element 2: Compliance with Standards The standards system addresses both internal and external
standards for design and engineering; national and international
Element 3: Corporate Process Safety Competency
codes and standards; and local, state regulations and laws. The
Element 4: Workplace Involvement system allows this information to be easily and quickly accessible to
Element 5: Stakeholder Outreach potential users, e.g. designers, engineers, vendors, etc.
Element 6: Process Knowledge Management
Element 7: HEMP Knowledge of and conformance to standards helps PDO to operate
and maintain a safe facility, consistently implement process safety
Element 8: Plant Operating Manuals
practices, and minimise legal liability. Changes in standards may
Element 9: PTW occur at irregular intervals or on a fixed schedule, and the standards
Element 10: Technical Integrity system must keep up with such changes so the company can adjust
Element 11: Contractor Management its compliance activities.
Element 12: Training and Performance Assurance
Scope of Element
Element 13: Management of Change
Element 14: Readiness for Start Up
The scope of this Element applies to all PDO assets during all phases
of the facility lifecycle, including: design, commissioning, start up,
shutdown, operations and decommissioning.
AI-PS Element Guide Implementation
Aims and Objectives of AI-PS Element Guide
The aim of this AI-PS Element Guide is to provide background to AI-
PS and a structured and consistent approach to carrying out Level 2
Self Assessments and Level 3 Verification for all AI-PS Elements
within PDO.
The intended audience for the guide are the members of the
AIPSALT although this can be used as a basis for training and
awareness for all staff at the asset.
Responsibilities and Accountabilities for AI-PS Element Guide
Implementation
The Operations Manager is accountable for the Level 2 Assurance
process at the asset.
Completion of the Level 2 Self Assessment and Level 3 Verification
Checklists, as provided in this element guide, is the responsibility of
the Element Champions and AIPSALT. The Delivery Team Leader
(DTL) is accountable for the AIPSALT.
AI-PS Assurance Leadership Team (AIPSALT)
The AIPSALT is comprised of the asset DTL and Process Safety
Element Champions (PSEC).
The DTL and PSEC roles include: reporting the status of the Level 3
Verification activities for the relevant Element at the AIPSALT
meeting; maintaining Key Performance Indicators (KPIs) for the
Element; monitoring the effectiveness of the Level 3 Verification
activities in assuring AI-PS, and recommending changes to improve
effectiveness and efficiency as appropriate; monitoring the progress
of corrective actions and improvement plans associated with that
Element; and leading Level 2 Self-Assessment of compliance with
the requirements of that Element.
Level 2 Assurance
Level 2 Self Assessment and Audit
Level 2 assurance is provided by a series of AI-PS audits carried out
on behalf of Asset Directors and Operations Managers as part of
their own Directorate-Level assurance processes.
Level 2 Audits (and Level 2 Self Assessments) are conducted at each
Directorate using standard protocols and templates described in
this series of AI-PS Element Guides.
The Level 2 Self Assessment Checklist (provided in this AI-PS
Element Guide) can be viewed as a ‘health check’ of asset
performance again the element. Completing the Level 2 Self
Assessment will help the asset to identify areas for improvement
ahead of the Level 2 Audit.
Frequency of Level 2 Assurance
Level 2 Audits are conducted annually at each Directorate but the
frequency and duration may be adjusted to reflect either positive or
negative trends, recent audit findings, emerging risks and alignment
with other audit activities. The schedule of Level 2 audits is set in
the Directorate HSE Plan.
The frequency of Level 2 Self Assessment should also reflect how
well the asset is performing against all AI-PS Elements and be
performed no less than on an annual basis (ahead of the Level 2
Audit).
Level 3 Verification Checklist
Verification Checklists
Level 3 Verification checklists have been developed for each AI-PS
Element within PDO in order to provide a structured and consistent
approach to Level 3 Verification across all assets. The Level 3
Verification checklists are structured as a sample check or specific
and localised audit of the Element in question.
By successfully verifying that the Level 3 Verification activities are
being completed correctly it provides a strong indication that the
element is being implemented at the ’system level’ (assessed via the
Level 2 Self Assessment and Level 2 Audits).

Level 3 Verification Description

The Level 2 Self Assessment and Level 3 verification checklists for
Level 3 Verification demonstrates compliance with the asset HSE this element are provided below.
Case ‘barriers’, HSE Critical Tasks, operational procedures and other
requirements defined in the HSE Management System. These
activities provide an ongoing check that the procedures, tests and
inspections necessary to maintaining the functionality of Safety
Critical Elements and systems are completed as required so that
process risk is managed to a level that is As Low As Reasonably
Practicable (ALARP).

In summary, the Level 3 Checklists are an operational level sample

check or ‘mini audit’, completed by the asset against PDO and asset
based procedures. The effectiveness of the Level 3 Verification
process is assessed during the Level 2 Self Assessment process and
ultimately via the Level 2 Audit programme.

Level 3 Verification is carried out by the AIPSALT, and may be

completed as per an agreed schedule or as required by ongoing
work. Typically it will be completed on a quarterly basis.
Level 2 Self Assessment
 SN Protocol
2.1 Have the relevant internal and external
codes and standards for the facility been
identified and documented? Specifically:
 Those that define equipment
design, construction, and
operations requirements for a
project or modification;
 Those that define training
requirements;
 Those that identify special or
unique hazards applicable to the
facility, e.g. Hydrogen Sulphide.
2.2 Are the relevant codes and standards
easily available to those who need them?
2.3 Have the relevant internal and external
codes and standards been properly
interpreted for the facility, its chemicals /
materials, and its operations, and
interpretations have been documented?
2.4 Are variances to codes, standards and
project specifications controlled in
accordance with PR-1247?
2.5 Is the facility using the current version of
codes and standards?
2.6 Have facility Technical Authorities (TA-2s)
been trained in the codes and standards
requirements and are competent to execute
the requirements?
Y / N / NA & Evidence Possible approach
The engineering manager(s), or persons in
similar positions are the most likely
interviewees for this protocol.
The engineering manager(s), or persons in
similar positions are the most likely
interviewees for this protocol.
For a project or modification, has a list of
DCAF deliverables been identified?
Has the list been approved or reviewed by
relevant discipline TA-2s?
Review Project Change Log.
For a project or modification, review the list
of selected codes and standards. Compare
against the version of GU-611 in force at
the time that the codes and standards were
selected. Are approved variances available,
when standards have not been selected?
For a project, review the Project Controls &
Assurance Plan (PCAP) to identify the TA-
2s assigned to the project. There TA
competency assessments should be held
by the Company DCAF manager.
Interview the TAs. Are they aware of the
latest version of codes and standards
relevant to their engineering discipline.
 SN Protocol Y / N / NA & Evidence Possible approach
2.7 Are facility Company Site Representatives Check awareness of a sample of codes and
aware of current codes and standards standards. Particularly those relevant to
applied by PDO? achieving Integrity in construction.
2.8 Are contractors familiar with the codes and Particularly the EMC/ODC contractors.
standards that govern their work? Review the documentation submitted by the
contractor during pre-qualification to
determine if the contractor understands the
codes and standards that govern the work.
Interview contractor personnel working at
the facility, particularly supervisors and
engineers, to determine if they understand
the codes and standards that govern their
work. Confirm that the codes and standards
are aligned to PDO standards and are the
latest revision.
 AI-PS Level 3 Compliance with Standards Verification Checklist

There is no Operate phase Level 3 Verification checklist for Compliance with Standards.