Guidance On Meeting Expectations of EI Process Safety Management Framework

Guidance on meeting expectations of
EI Process safety management framework
Element 2: Identification and compliance

with legislation and industry standards
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GUIDANCE ON MEETING EXPECTATIONS OF
EI PROCESS SAFETY MANAGEMENT FRAMEWORK ELEMENT 2:
IDENTIFICATION AND COMPLIANCE WITH LEGISLATION AND INDUSTRY STANDARDS
1st edition
October 2013
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GUIDANCE ON MEETING EXPECTATIONS OF EI PROCESS SAFETY MANAGEMENT FRAMEWORK
ELEMENT 2: IDENTIFICATION AND COMPLIANCE WITH LEGISLATION AND INDUSTRY STANDARDS
CONTENTS
Page
Publications in this series . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Foreword . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Acknowledgements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
1.1 Identification and compliance with legislation and industry standards . . . . . . . . . . . . 7
1.2 Expectations for element 2: Identification and compliance with legislation
and industry standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2 Arrangements for meeting expectations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.1 Descriptions of actions for each step in the logical flow diagram . . . . . . . . . . . . . . . 11
3 Suggested compliance checks and performance measure . . . . . . . . . . . . . . . . . . . . . 21

3.1 Performance measure 1: Element compliance and implementation status
(EIPSS rating) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.2 Performance measure 2: Review and implementation of legislation
and industry standards . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
3.3 Performance measure 3: Identified non-compliances with new legislation
and industry standards . . . . . . . . . . . . . . . . . . . . . . . . . . 24
3.4 Performance measure 4: Observed non-compliances with new legislation
and industry standards �� 26
3.5 Performance measure 5: Overdue field observations . . . . . . . . . . . . . . . . . . . . . . . . 28
3.6 Performance measure 6: Incident root causes which are failures of element 2 . . . . . 29
Annexes
Annex A References and bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

A.1 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
A.2 Further resources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
Annex B Glossary of acronyms and abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
Annex C Mapping of process steps to EI PSM framework expectations . . . . . . . . . . . . 33
Annex D Example report template: Management and supervisory

field observation �� 34
PUBLICATIONS IN THIS SERIES
Guidance on meeting expectations of EI Process safety management framework

−− Element 1: Leadership, commitment and responsibility
−− Element 2: Identification and compliance with legislation and industry standards
−− Element 3: Employee selection, placement and competency, and health assurance
−− Element 4: Workforce involvement
−− Element 5: Communication with stakeholders
−− Element 6: Hazard identification and risk assessment
−− Element 7: Documentation, records and knowledge management
−− Element 8: Operating manuals and procedures
−− Element 9: Process and operational status monitoring, and handover
−− Element 10: Management of operational interfaces
−− Element 11: Standards and practices
−− Element 12: Management of change and project management
−− Element 13: Operational readiness and process start-up
−− Element 14: Emergency preparedness
−− Element 15: Inspection and maintenance
−− Element 16: Management of safety critical devices
−− Element 17: Work control, permit to work and task risk management
−− Element 18: Contractor and supplier, selection and management
−− Element 19: Incident reporting and investigation
−− Element 20: Audit, assurance, management review and intervention
FOREWORD
Process safety management (PSM) is vital to ensuring safe and continued operations in major accident
hazard (MAH) organisations. However, PSM is a multifaceted process, and a number of high profile
incidents since 2005 have suggested that without a holistic understanding of the various factors
required for effective PSM it can be difficult and inefficient to ensure, and measure, performance.
In 2010 the Energy Institute (EI) published High level framework for process safety management (PSM
framework), which aimed to define what PSM should involve. Divided into four focus areas (process
safety leadership, risk identification and assessment, risk management, and review and improvement)
and sub-divided into 20 'elements', it sets out a framework of activities MAH organisations should
undertake to ensure PSM. Each element lists a number of high level activities organisations should
meet (expectations).
EI Guidance on meeting expectations of EI Process safety management framework is a series of 20

publications ('guidelines') that build on the PSM framework. Commissioned by the EI Process Safety
Committee (PSC) each guideline captures and presents current industry good practices and guidance
on how organisations can meet the expectations set out in each element of the PSM framework.
Each guideline includes:
−− A logical flow diagram of activities ('steps') the organisation should undertake to
manage that element.
−− Descriptions of those steps.
−− Example performance measures (PMs) to measure the extent to which key steps have
been undertaken.
−− A list of further resources to help undertake key steps.
−− A table mapping the steps against the expectations in the PSM framework.
−− Annexes of useful information.
Readers implementing the guidance in this publication should be aware of the PSM framework and
the other publications in this series, particularly if they are a manager with oversight of the wider
implementation of PSM.
The information contained in this publication is provided for general information purposes only.
Whilst the EI and the contributors have applied reasonable care in developing this publication, no
representations or warranties, express or implied, are made by the EI or any of the contributors
concerning the applicability, suitability, accuracy or completeness of the information contained herein
and the EI and the contributors accept no responsibility whatsoever for the use of this information.
Neither the EI nor any of the contributors shall be liable in any way for any liability, loss, cost or
damage incurred as a result of the receipt or use of the information contained herein.
Suggested revisions are invited and should be submitted through the Technical Department, Energy
Institute, 61 New Cavendish Street, London, W1G 7AR. e: technical@energyinst.org
ACKNOWLEDGEMENTS
EI Guidance on meeting expectations of EI Process safety management framework was commissioned

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

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

John Armstrong E.ON
Mike Beanland ABB
Amanda Cockton Health and Safety Executive
Edwin Ebiegbe E.ON
Allen Ormond ABB
Technical editing was carried out by Stuart King (EI).
Affiliations are correct at the time of contribution.
1 INTRODUCTION
1.1 Identification and compliance with legislation and industry

standards
This guideline sets out good practices for the identification and compliance with legislation
and industry standards. Compliance with legislation is a fundamental requirement for
organisations. Management should ensure that requirements of applicable legislation are
identified, understood and complied with.
The scope of this element is to ensure that the organisation’s arrangements meet the
requirements of the applicable legislation and industry standards; consequently it focuses on
the arrangements themselves, rather than compliance with the arrangements. The checking
of compliance with the arrangements is covered by other elements.
This element defines what should be done to ensure that the organisation meets the
requirements of legislation, typically by identifying required design standards, safe working
practices, policies and procedures. Consequently this element works in conjunction with the
following other elements:
−− Element 1 – Leadership, commitment and responsibility;
– policies;
– targets, objectives and action plans;
−− Element 8 – Operating manuals and procedures;
– procedures;
−− Element 11 – Standards and practices;
– design standards, and
– safe working practices.
1.2 Expectations for element 2: identification and compliance with

legislation and industry standards
Element 2 of EI High level framework for process safety management (PSM framework)
describes five expectations – arrangements and processes that organisations should (to an
appropriate degree) have in place in order to ensure they are managing this aspect of PSM
appropriately:
'Overview Compliance with legislation is a fundamental requirement for organisations.
Management must ensure that the requirements of applicable legislation
are identified, understood and complied with.
2.1 Requirements of current and forthcoming, applicable legislation,

regulations, licences, permits, codes, standards, practices and other
governmental requirements are identified, documented and kept current.
2.2 The operating requirements arising from legislation and industry standards
are defined, documented and communicated to those affected.
2.3 Compliance with legislation and industry standards is systematically

verified.
2.4 Arrangements for identification and compliance with legislation and

industry standards are understood and followed; understanding of
arrangements and compliance with them is regularly tested.
2.5 Compliance and performance trends are reviewed by specified levels of

management.'
This guideline provides a process, along with guidance, to help organisations meet these
expectations. It also suggests a number of compliance checks and performance measures
(PMs) to measure the extent to which key activities involved in meeting these expectations
have been or are being undertaken.
2 ARRANGEMENTS FOR MEETING EXPECTATIONS
Figure 1 provides a logical flow diagram for the activities that should be in place to meet the
expectations in element 2, to manage the identification and compliance with legislation and
industry standards relating to PSM. It covers activities (steps) which should be undertaken by
the organisation, across three phases: set-up (preparations to manage the element); operate
(management of the element); and monitor, review and intervene (monitoring and reviewing
the management of the element, and making appropriate interventions if the element is not
being managed effectively).
The flow diagram provides an example of the logical arrangement of necessary
activities. The reader should take cues from the arrangement and relationships between
steps when determining the appropriate flow design for their own organisation. The flow
diagram also shows interfaces with other elements, where this element may be dependent
upon activities that are addressed by other elements – e.g. step 2 relies on their being an
effective competence management system in place, as described in Guidance on meeting
expectations of EI Process safety management framework Element 3: Employee selection,
placement and competency, and health assurance.
At specific points in the flow diagram process, PMs are suggested. These PMs are
predominantly leading indicators designed to enable the measurement of the outputs from
the element and the level of operational compliance with the expectations. Suggested PMs
are described further in Section 3.
2.1 provides guidance on the actions involved for each step, the deliverables that
should result from those actions, and the frequency at which the step should be undertaken.
It also provides more detailed guidance notes.
These steps have been mapped against element 2 expectations in Annex C. Note
that some expectations are fulfilled through several steps, and some steps help fulfil several
expectations, however all steps should be undertaken. As such, Annex C is for reference
purposes only, to demonstrate that the arrangements outlined in this guideline enable the
organisation to work towards fulfilling the requirements set out in element 2 of EI PSM
framework.
Set-up
01 02 03 04
Identify and appoint Ensure assigned Identify
Define review
responsible persons; define responsible persons applicable Element
frequency
delegated authorities for are competent legislation 3
decision making
05
Changes to:
assets, Monitor and identify
organisations, new or changed
operation legislation and industry
standards
06
Assess applicability of legislation
and industry standards and
New or changed:
develop synopsis of requirements
legislation,
industry, standards
07
Review and identify
implications of legislation and
industry standards
2
No 08b
08a
Inspection and No 08c No 08d No 08e
Design standard Safe working practice Policy or procedural Investment project
maintenance standard
required? required? change required? required?
required?
No
Yes Yes Yes Yes
Yes
08f
Develop plans to meet

legislation and
industry standards
09a Rejected No
09b
Review and Revise plans?
Element 1 approve
Element 8
Yes
Element 11
Approved
10a 10b
Consider
Implement
stopping
approved plans
activity
Element
3 7
1 11 12
Operate 4 Confirm that DS, SWP
Publish and
or P&P meet legislation
5 6 update records
and industry standards
13 14 15 6
Performance measurement Performance and Annual review of effectiveness and

and compliance checking compliance trend analysis sustainability of element arrangements
Performance
16 measures
Monitor, review and intervene Management review and
control meetings
Figure 1: Logical flow diagram
10
2.1 Descriptions of actions for each step in the logical flow diagram
Step Actions Deliverables Frequency

01 Identify and appoint Defined roles and During implementation;
responsible persons; responsibilities. then as required.
define delegated Agreed list of
authorities for responsible persons
decision making. who will:
Identify and appoint −− act as element
persons who will owner, and
have defined roles −− carry out each aspect
and responsibilities of the arrangements
for each aspect of for the element.
the arrangements Defined delegated
for identification authorities for decision
and compliance with making.
legislation and industry
standards. Agreed list of delegated
authorities for each
identified responsible
person/position.
Guidance notes:
The senior accountable person, typically a director, business unit (BU) leader or site
manager, should ensure that accountabilities and responsibilities are assigned for each
step in the process. Typically this can be achieved by appointing an element owner
who will work with line managers to agree and assign these accountabilities and
responsibilities.
Typically, the element owner should be a senior line manager.
During the implementation phase the element owner should coordinate the
implementation of the element across the organisation, BU or site on behalf of the
senior accountable person, working with other senior line managers to ensure that the
implementation is appropriately planned and resourced and that any issues are resolved.
The element owner should also ensure that delegated authorities for decision making
within the element are defined and approved.
It should be ensured that the requirements and implications of legislation and industry
standards and plans to address the identified requirements are reviewed and authorised
by persons who are competent and authorised to do so.
The organisation should decide who will have delegated authority and maintain an up-
to-date record of persons with delegated authorities to:
−− identify applicable legislation and industry standards.
−− represent the company on industry groups which are consulted during the
development of new or changed legislation and industry standards.
−− identify requirements of applicable legislation and industry standards.
−− identify implications of applicable legislation and industry standards.
−− plans to address the identified requirements.
Technical authority should be delegated to persons with the appropriate technical
competencies to make the decision.
11

Guidance notes continued...
Management authority should be delegated to an appropriate level of line management
with responsibility for the operation of the business and an appropriate understanding
of the business implications of the requirements of the legislation and industry
standards.
Following implementation, during the operational phase the element owner should
work with the other senior line managers to ensure that the element continues
to operate as intended. In effect the element owner should act as a coach to the
management team, building their understanding and confidence in the use of the
element.
02 Ensure competence Training material. During implementation;
of appointed Competency then as required.
responsible persons. assessment.
Define required HS&E Training schedule.
and process safety
attributes and example Competent persons.
behaviours for each
level and integrate
into the organisation’s
competency
framework (see
Guidance on meeting
expectations of
EI Process safety
management
framework Element 3:
Employee selection,
placement and
competency, and
health assurance).
Guidance notes:
The element owner should ensure that the required competencies are defined and
agreed for all persons with assigned roles and responsibilities within the element,
and that each of these persons is trained and coached appropriately to develop these
required competencies.
They should also ensure that training and development programmes and routine
personnel performance appraisals take into account these required competencies.
This should be accomplished by means of Guidance on meeting expectations of EI
Process safety management framework Element 3: Employee selection, placement and
competency, and health assurance.
03 Identify applicable Comprehensive register During implementation;
legislation. of applicable legislation then as required.
and industry standards.
12

03 Register should
cont. identify which part of
the organisation the
identified legislation or
industry standards are
applicable to.
Guidance notes:
The element owner should ensure that there is a listing of existing applicable legislation
and industry standards and that it is comprehensive and correct and that there are
arrangements in place to ensure that this listing is kept up to date.
04 Define review Defined review During implementation;
frequencies. frequencies for then as required.
Define review applicable legislation
frequencies for the and industry standards.
applicable legislation
Guidance notes:
Identified applicable legislation and industry standards should be reviewed on a routine
basis to ensure that the assessment of requirements and implications is up to date
and incorporates any changes to the legislation and industry standards. The BU should
ensure that an appropriate review frequency is defined.
05 Monitor for and Identified new As required by the
identify new or applicable legislation. schedule.
changed applicable Identified changed
legislation and legislation.
industry standards.
Identified new
applicable industry
standards.
Identified changed
industry standards.
Guidance notes:
The element owner should ensure that resources are assigned to monitor for new,
changed or forthcoming legislation and industry standards.
It is likely that the organisation will have nominated persons who sit on industry groups
which are consulted during the development of new or changed legislation and industry
standards. These persons will have the opportunity to represent the company’s position
during the consultation and hence potentially influence the shaping of the legislation
and industry standards. Persons representing the company on these groups should
have the necessary technical competencies and have the appropriate delegated level of
authority.
13

06 Assess applicability Synopsis of the As required by the
of legislation legislation and industry schedule.
and industry standards, setting
standards and out its purpose and a
develop synopsis of summary of what is
requirements. required by it.
Guidance notes:
Legislation and industry standards can often be written in such a way that it is not
easy to understand their meaning or requirements. The organisation should ensure
that an appropriately competent person assesses the requirements of each item of
new legislation or industry standard and develops an easily understood synopsis of its
requirements.
07 Review and identify Management brief As required by the
implications of identifying the schedule.
legislation and implications of the
industry standards. legislation and industry
Review organisation standards:
wide and BU/ −− Identified non-
operating site-specific compliances with
implications of new or changed
legislation and industry legislation or industry
standards. Develop standards.
an appropriate −− Organisation wide
management brief. implications.
−− BU/operating site
specific implications.
08a, Legislation and Identified requirement As required by the
08b, industry standards. to develop or update: schedule.
08c, Assess what is −− design standard;
08d, required to meet the −− inspection and
08e requirements of the maintenance
legislation and industry standard;
standards. −− safe working
practice, and
−− policy or procedures.
Identified requirement
to develop an
investment project.
Identified need to stop
activity.
Guidance notes:
The organisation should ensure that the requirements of the legislation and industry
standards are reviewed in order to identify the implications for their specific business.
Typically implications will be one or more of the following:
−− new or revised design standards;
−− new or revised inspection and maintenance standards;
−− new or revised safe working practices;
14

Guidance notes continued...
−− new or revised policies or procedures, and
−− an investment project to provide new or modified assets or equipment.
In some circumstances the organisation may decide not to adopt all or part of an
industry standard. In these cases the rationale for this decision should be documented
and reviewed and approved by the persons with the appropriate delegated level of
authority.
08f Develop plans to Resourced plans and As required by the
meet legislation and schedules for what schedule.
industry standards. needs to be done to
Develop resourced meet requirements of
plans and schedules legislation and industry
for what needs to standards.
be done to meet
standards.
Guidance notes:
The organisation should develop realistic, resourced plans and schedules to address the
requirements of the identified applicable legislation and industry standards.
In some cases the requirements and implications of the legislation and industry
standards may be such that it is not economically justifiable to do so; in these cases the
organisation should consider stopping the activity or withdrawing from the impacted
area of business. Decisions of this nature should be included in the plans.
09a/b Review and approve. Approved fully funded As required by the
Review and approve and fully resourced schedule.
plans and schedules. plans and schedules for
what needs to be done
Revise plans as to meet requirements of
needed. legislation.
Requirement to revise
plans.
Decision to consider
stopping the operation
or activity.
Guidance notes:
Completed assessment of requirements and implications of the legislation and industry
standards, together with plans and schedules to address the requirements, should be
reviewed and approved by the persons with the appropriate delegated level of authority.
In cases where they are not satisfied they should ensure the assessment or the plans and
schedules are revised accordingly.
15

10a Implement approved Completed risk As required by the
plans. assessment on the schedule cycle.
Implement plans to activity identifying
meet legislation and required control
industry standards. measures to continue
operation, with
economic assessment
of required control
measures.
Work required to meet
standards completed in
full and in line with plan
and schedule.
Affected personnel
briefed on
requirements,
implications and plans.
Compliance with
standards.
10b Consider stopping Completed risk As required by the
activity. assessment on the schedule cycle
Consider stopping activity identifying
the activity if it is not required control
feasible to comply with measures to continue
legislation and industry operation, with
standards. economic assessment
of required control
measures.
Plan to stop activity
developed, approved
and implemented.
Affected personnel
briefed on
requirements,
implications and plans.
Operation or activity
stopped.
Decision to continue
activity and do what is
required to comply with
standards.
16

11 Confirm that DS, Confirmation that As required by the
SWP or P&P meet implemented: schedule.
legislation and −− design standards;
industry standards. −− inspection and
Check and confirm maintenance
that implemented: standards;
−− design standards; −− safe working
−− inspection and practices;
maintenance −− policy and
standards; procedures, and
−− safe working −− investment projects
practices; comply with the
−− policy and requirements of
procedures, and applicable legislation
−− investment projects and industry
comply with the standards.
requirements of
and industry
standards.
Guidance notes:
Risk assessments should be carried out on activities in order to assess the required
control measures to meet the applicable legislation. An economic assessment should
be carried out on the required control measures in order to determine whether it
is economic to implement the control measures or, in the event of them not being
economical, the activity or operation should be stopped.
The organisation should ensure that the approved plans to address requirements of the
legislation and industry standards are implemented in line with the agreed schedules.
Affected personnel should be briefed on requirements, implications and plans.
The organisation should also ensure that checks are carried out to confirm that the
implemented arrangements meet the requirements of the applicable legislation and
industry standards.
The scope of this element is to ensure that the organisation’s arrangements meet
the requirements of the applicable legislation and industry standards; consequently
this checking should focus on the arrangements rather than compliance with the
arrangements. The checking of compliance with the arrangements is covered by other
elements:
−− Element 1 – Leadership, commitment and responsibility;
−− policies;
−− targets, objectives and action plans;
−− Element 8 – Operating manuals and procedures;
−− procedures;
−− Element 11 – Standards and practices;
−− design standards, and
−− safe working practices.
17

12 Publish and update Defined and agreed As required by the
records. approach to where schedule.
Define and agree what and how register of
records are required, applicable legislation
and where and how and industry standards
they will be held and will be held.
version controlled. Defined and agreed
Ensure required records approach to ensure that
are readily available to register of applicable
those who need to use legislation and industry
them. standards is readily
available to those who
need to use them.
Defined accountability
and responsibilities for
maintaining register of
Defined and agreed
approach to where and
how records will be
held for:
−− Requirements of
and industry
standards.
−− Management brief
identifying the
implications of
the legislation and
industry standards.
Guidance notes:
The organisation should define the required documentation and records to support
this element. They should define what is required, how and where it will be held, the
retention policy, how it will be made available to those who need to use it, and who will
be responsible for maintaining these documents and records.
13 Performance Defined PMs. As required by the
measurement and PMs generated in line schedule.
compliance checking. with the schedule.
Establish and Compliance checking
implement PMs. programme.
Establish regular Completed compliance
management and checks.
supervisory compliance
checks. Identified necessary
interventions.
18

Guidance notes:
A systematic set of PMs should be defined in order to enable each BU or site to monitor
and confirm compliance with the element and to draw attention to any areas of non-
compliance.
In order to maintain effective control, the element owner should ensure that
accountability for performance against each PM is clearly identified and that the
accountable person understands the interventions that need to be made to correct
deviations in performance against the PM.
The element owner should ensure that PMs are reviewed by an appropriate level of
management on a routine scheduled basis.
The suggested PMs are defined in section 3 of this guideline.
14 Performance and A report on trends Monthly.
compliance trend identified, for review:
analysis. −− at appropriate
PMs and findings management
from compliance meetings;
checks are analysed to −− by BU executive, and
identify any emerging −− by company
underlying trends. executive.
Guidance notes:
This guideline defines suggested PMs which will allow the BU or site to monitor
compliance with the element. This is an important aspect of management control
but it does not provide the whole picture. Findings from compliance checking and
performance monitoring should be reviewed and analysed in order to identify any
underlying trends. The trends which should be monitored and analysed should also be
adapted according to performance and the issues being managed during any particular
time period. However, the key issue is to ensure that resource is assigned to carry out
this monitoring and analysis and that this trend analysis is carried out on a routine basis
and presented for review at appropriate management meetings.
15 Annual review A report identifying: Annually.
of effectiveness −− issues requiring
and sustainability resolution, and
of element −− opportunities
arrangements. to enhance the
Review of the arrangements.
arrangements to
check that they
are functioning as
intended and are still
fit for purpose.
19

Guidance notes:
The element owner is required to initiate an annual review of the element in order to
check that it is still functioning as intended and that it is still fit for purpose, identifying
any issues requiring resolution or any opportunities to enhance the implementation of
the element.
The element owner should ensure that appropriate employees and employees’
representatives are involved in developing input to this review.
16 Management PMs and trend analysis Monthly.
review and control reviewed at appropriate
meetings. management meetings
Management review by:
and control meetings −− local line
by the appropriate management;
levels of management. −− BU Executive, and
−− company executive.
Systematic review of
defined PM sets. Management of the
findings from the
Review emerging annual review.
issues identified by the
analysis of trends. Appropriate
interventions to correct
Manage issues and deviations from required
opportunities identified performance.
by annual review of
the process. Specific interventions.
Appropriate
interventions.
Guidance notes:
The element owner should ensure that the review of the PMs is incorporated into
appropriate management control meetings. It is likely that it will be necessary to
incorporate the PMs into meetings at a number of different levels. For example, they
may need to be incorporated into executive meetings and into senior management
team meetings. The scope of any PMs should be matched to the area of the business
which is being reviewed at each meeting.
The management control meetings should focus on deviations from the required
performance, identifying necessary interventions to correct performance.
The PMs and the output from these management control meetings may provide input
to appropriate health and safety committees.
20
3 SUGGESTED COMPLIANCE CHECKS AND PERFORMANCE

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

The suggested implementation PMs can be used during the implementation phase to
measure and monitor progress with the implementation of the arrangements for identification
and implementation of new legislation and standards.
The suggested operational PMs can be used to measure compliance with the element
as part of normal operation. The reader should refer to Figure 1 to indicate which PMs are
relevant to which steps.
The suggested measures identify aspects of performance that should be controlled
in order to assure the integrity of the operation. In order to be controlled they should be
measured by someone in the organisation – if they aren’t measured they are unlikely to be
controlled.
The level of measurement should be appropriate for the business, taking into account
the risk to the business associated with each parameter being out of control. The required
frequency of measurement and checking may vary according to the level of demonstrated
performance; if the performance of a parameter is demonstrated to be under control then
the measurement and checking interval may be extended. However, if the performance of the
parameter is shown to be unacceptable the interval should be reduced. It should be ensured
that there is a frequency of measurement and checking which assures an appropriate level
of control.
Table 1: Performance measures for element 2
No. Type Performance measure

1 Compliance and implementation Element compliance and
implementation status (EIPSS rating)
2 Compliance and implementation Review and implementation of
3 Operational Identified non-compliances with new
4 Operational Observed non-compliances with new
5 Operational Overdue field observations
6 Outcome Incident root causes which are failures
of element 2
21
3.1 Performance measure 1: Element compliance and implementation

status EIPSS rating
This PM enables management to monitor the implementation and compliance of the element
of the EI PSM framework. It makes use of the EI Process Safety Survey (EIPSS) to enable the
business to carry out a systematic self-assessment of its compliance with the expectations of
element 1.
The EIPSS can be used for a base line assessment of compliance, which can then
be updated as those responsible close each of the individual identified gaps. In this way
it provides management with an easily developed continuously updated assessment of
implementation and compliance.
The line manager accountable for implementation should make a corrective
intervention if the actual progress falls below plan. It is likely the required interventions would
be either to adjust priorities to create space to allow this work to be done, to make additional
resource available, or to reset the schedule to reflect what can be achieved realistically with
the assigned resource.
Table 2: Element compliance and implementation status EIPSS rating – PM overview
Type Required data Representation

Implementation and By month: Line and bar graph:
operational −− current element 2, −− target overall element
target EIPSS overall rating (line);
rating; −− overall element rating
−− current element 2, (bar)
actual EIPSS overall −− documented
rating; arrangements rating
−− current element 2, (line);
EIPSS documented −− implementation rating
arrangements rating, (line).
and
−− current element 2, EIPSS
implementation rating.
Element 2
Compliance and implementation status
Overall status Implementation Documented arrangements Target overall status
Figure 2: Suggested presentation of PM 1
22
3.2 Performance measure 2: Review and implementation of legislation and

industry standards
This PM enables management to monitor implementation progress, tracking the number of

identified items of legislation and the number of industry standards and the progress against
a schedule for their review and implementation.
The line manager accountable for review and implementation of legislation and
industry standards should make a corrective intervention if the actual progress falls behind
plan. It is likely the required interventions would be either to adjust priorities to create space
to allow this work to be done, to make additional resource available, or to reset the schedule
to reflect what can be achieved realistically with the assigned resource.
Table 3: Review and implementation of legislation and industry standards – PM

overview

Implementation/ Progress against schedule Bar/line graph
operational By month:
−− cumulative number
of items of legislation
and industry standards
identified;
−− cumulative scheduled
number of items
to be reviewed and
implemented;
−− cumulative actual
number of items
reviewed and
implemented, and
−− number of items
overdue.
Legislation and industry standards - review and

implementation
Progress against target
14
No. of items of legislation
12
10
8
6
4
2
0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Identified Completed Overdue Scheduled
23
3.3 Performance measure 3: Identified non-compliances with new

This PM enables management to monitor the number of non-compliances that have

been discovered and are still outstanding following the review of legislation and industry
standards, and to track the number and severity of non-compliances outstanding. It is likely
that the graphical representation would be supported by a list of each of the outstanding
non-compliances when identified, a plan to resolve them and the responsible line manager.
The accountable line manager should make an intervention if the trends are adverse
or are not showing underlying improvement.
Table 4: Identified non-compliances with new legislation and industry standards –

PM overview

Operational By month: Stacked bar graph:
−− Legislation: −− Legislation:
−− number of outstanding −− major non-compliances, and
major non-compliances, and −− minor non-compliances.
−− number of outstanding −− Industry standards:
minor non-compliances. −− major non-compliances, and
−− Industry standards: −− minor non-compliances.
−− number of outstanding
major non-compliances, and
−− number of outstanding
minor non-compliances.
Note: organisations should define
what they consider to be a major
non-compliance and what they
consider to be a minor non-
compliance. It may be appropriate
to consider situations where
legislation or industry standards
are applied so far as is reasonably
practicable (SAFIRP) as 'minor non-
compliances'.
24
Industry standards - outstanding non-compliances
35
No. of non-compliances
30
25
20
15
10
5
0
Minor Major
25
3.4 Performance measure 4: Observed non-compliances with new

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

legislation and industry standards, tracking the numbers of non-compliances that have been
identified during management and supervision field checks. It is likely that the graphical
representation would be supported by a list of each of the identified non-compliances when
identified, a plan to resolve them and the responsible line manager.
The field inspection should be a combination of checking compliance with this
process and checking compliance with applicable legislation and industry standards, with the
emphasis on providing evidence of compliance in the field. The checking should either start
with a specific standard or safe working practice and sample check compliance with it in the
field, or looking at an activity in the field and questioning what standards are applicable and
checking compliance with them. The field checks should be carried out by personnel with
appropriate competence and experience. Annex D provides a suggested template for field
observations.
The accountable line manager should make an intervention if the trends are adverse
or are not showing underlying improvement.
Table 5: Observed non-compliances – PM overview

Operational Observed non-compliances Stacked bar graph:
with legislation and −− Legislation:
industry standards. −− major non-
By month: compliances, and
−− Process: −− minor non-
−− number of identified compliances.
major non- −− Industry standards:
compliances, and −− major non-
−− number of identified compliances, and
minor non- −− minor non-
compliances. compliances.
−− Legislation:
−− number of identified
major non-
compliances, and
minor non-
compliances.
−− Industry standards:
major non-
compliances, and
minor non-
compliances.
26
Legislation - outstanding non-compliances
12
10
8
6
4
2
0
Minor Major
Industry standards - outstanding non-compliances
35
30
25
20
15
10
5
0
Minor Major
27
3.5 Performance measure 5: Overdue field observations
This PM enables management to monitor whether the scheduled management and supervisory
field observations have been carried out, tracking the number of field observations overdue.
It is likely that this PM would be supported by a list showing each of the field observations
overdue and who the responsible line managers are in each case.
The accountable line manager will need to make an intervention if there are any field
observations overdue.
It is likely that the required intervention would be to directly request the appropriate
line manager to ensure that the outstanding field observations are completed before the next
management control meeting, and to question why they were not done and what needs
to be done to ensure that they are done in future. Typically this will require adjustment of
priorities and reassigning work activities to create space to allow this work to be done. If the
situation continues for some time it is likely to be indicative of an underlying issue with either
resource levels or time planning.
Table 6: Overdue field observations – PM overview

Operational By month: Bar graph
−− the number of field
observations overdue.
Overdue field observations

5
4
No. overdue
0
Overdue
28
3.6 Performance measure 6: Incident root causes which are failures of

Element 2
This PM enables management to monitor the trend of the number of times a failure of
some aspect of element 2 is identified as a root cause of an incident (Guidance on meeting
expectations of EI Process safety management framework Element 19: Incident reporting
and investigation provides guidance on how root causes should be aligned with failures of EI
PSM framework elements). This information can assist line managers to understand whether
their arrangements for meeting the expectations of element 2 are achieving the required
outcome.
A constant or increasing number of root causes associated with a failure of this
element would indicate that there is a need to review the effectiveness of the arrangements
and their implementation.
Table 7: Incident root causes which are failures of element 2 – PM overview

Analysis of trends By month: Stacked bar:
−− number of incident −− very serious iincidents;
root causes which are −− serious incidents, and
failures of element 2, −− incidents.
categorised as root
causes of:
−− very serious incidents;
−− serious incidents, and
−− incidents.
Incident root causes

which are failures of Element 2
14
12
No. of root causes
10
0
I SI VSI
29
ANNEX A
references and BIBLIOGRAPHY
A.1 References
EI, High level framework for process safety management

http://www.energyinst.org/psm-framework
A.2 Further resources
This section contains a non-exhaustive list of further resources to help organisations

implement element 2. Resources include pertinent guidance publications, codes of practice,
standards, and practical tools.
Description Step
ANSI American National Standards Institute website, 03, 06,
http://www.ansi.org/ 07, 08f
BSI British Standards Institute website, 03, 06,
http://www.bsigroup.co.uk/ 07, 08f
EC European Commission website, 03, 06,
http://ec.europa.eu/legislation/index_en.htm 07, 08f
CEN European Committee for Standardisation website, 03, 06,
http://www.cen.eu/cen/products/en/pages/default.aspx 07, 08f
ISO International Standards Organisation website, 03, 06,
http://www.iso.org 07, 08f
HSE A step-by-step guide for the chemical and major hazard industries, 13,14
http://books.hse.gov.uk/hse/public/saleproduct. 15,16
jsf?catalogueCode=9780717661800
HSE Health and Safety Executive website, Health and safety 03, 06,
legislation–laws in the workplace, 07, 08f
http://www.hse.gov.uk/legislation/index.htm
HSE Health and Safety Executive website, Offshore health and safety 03, 06,
law, 07, 08f
http://www.hse.gov.uk/offshore/law.htm?eban=rss-legislation
IOD/ Leading Health and Safety at Work: Leadership Actions for 01, 02,
HSE Directors and Board Members, 13,14
http://www.hse.gov.uk/leadership 15,16
http://www.iod.com/hsguide
UK The National Archives website, 03, 06,
http://www.legislation.gov.uk 07, 08f
US United States Department of Labor website, 03, 06,
DOL http://www.osha.gov/ 07, 08f
30
Description Step
US United States Environmental Protection Agency website, 03, 06,
EPA http://www.epa.gov/lawsregs/sectors/index.html 07, 08f
31
ANNEX B
GLOSSARY OF acronyms and ABBREVIATIONS
ANSI American National Standards Institute

BSI British Standards Institute
BU business unit
CEN Comité Européen de Normalisation (European Committee for Standardisation)
EC European Commission
EIPSS Energy Institute Process safety survey
HS&E health, safety and environment
HSE Health and Safety Executive
ISO International Standards Organisation
MS management system
PM performance measure
SAFIRP so far as is reasonably practicable
32
ANNEX C
Mapping of process steps to EI PSM framework Expectations
Table C1: Mapping of process steps to EI PSM framework expectations for element 2
Step number
01 02 03 04 05 06 07 08a 08b 08c 08d 08e 08f 09a 09b 10a 10b 11 12 13 14 15 16
2.1 Requirements of current and

forthcoming applicable legislation,
regulations, licences, permits, codes,
standards, practices and other
governmental requirements are
identified, documented and kept
current.
33
2.2 The operating requirements arising
from legislation and industry standards
are defined, documented and
communicated to those affected.
2.3 Compliance with legislation and industry
standards is systematically verified.
2.4 Arrangements for identification and
compliance with legislation and industry
standards are understood and followed;
understanding of arrangements and
compliance with them is regularly
tested.
2.5 Compliance and performance trends

are reviewed by specified levels of
managment.
ANNEX D
EXAMPLE REPORT TEMPLATE: MANAGEMENT AND
SUPERVISORY FIELD OBSERVATION
Management and supervisory field observation report

Location: Date:
Work group leader: Observer:
Rating Comments
1 2 3 4 n/a
Is the legislation or
industry standard up to
date?
Are the personnel
aware of the legislation
or industry standard
required?
Are legislation and
industry standard fully
implemented into the
business?
Are personnel using
appropriate standards and
practices for the legislation
and industry standard?
1 = Major deficiency identified 2 = Minor deficiency identified

3 = Meets expectations 4 = Exceeds expectations
Note: Organisations should define what will be considered as major and minor deficiencies; the
use of the risk matrix may assist with this.
34
This publication has been produced as a result of
work carried out within the Technical Team of the
Energy Institute (EI), funded by the EI’s Technical
Partners and other stakeholders. The EI’s Technical
Work Programme provides industry with cost
effective, value adding knowledge on key current
and future issues affecting those operating in the
Energy Institute energy sector, both in the UK and beyond.
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London W1G 7AR, UK
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Guidance on meeting expectations of

EI Process safety management framework

Element 2: Identification and compliance

IDENTIFICATION AND COMPLIANCE WITH LEGISLATION AND INDUSTRY STANDARDS

The EI is licensed by:

For further information, please visit http://www.energyinst.org

BG Group Premier Oil

Copyright © 2013 by the Energy Institute, London.

ISBN 978 0 85293 657 3

Published by the Energy Institute

Electronic access to EI and IP publications is available via our website, www.energypublishing.org.

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

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

3 Suggested compliance checks and performance measure . . . . . . . . . . . . . . . . . . . . . 21

Annex A References and bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Annex B Glossary of acronyms and abbreviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Annex C Mapping of process steps to EI PSM framework expectations . . . . . . . . . . . . 33

Annex D Example report template: Management and supervisory

PUBLICATIONS IN THIS SERIES

Guidance on meeting expectations of EI Process safety management framework

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

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

Martin Ball Bossiney Consulting

Lee Allford European Process Safety Centre

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

Affiliations are correct at the time of contribution.

1.1 Identification and compliance with legislation and industry

1.2 Expectations for element 2: identification and compliance with

2.1 Requirements of current and forthcoming, applicable legislation,

2.3 Compliance with legislation and industry standards is systematically

2.4 Arrangements for identification and compliance with legislation and

2.5 Compliance and performance trends are reviewed by specified levels of

2 ARRANGEMENTS FOR MEETING EXPECTATIONS

Develop plans to meet

Performance measurement Performance and Annual review of effectiveness and

Figure 1: Logical flow diagram

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

Step Actions Deliverables Frequency

3 SUGGESTED COMPLIANCE CHECKS AND PERFORMANCE

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

Table 1: Performance measures for element 2

No. Type Performance measure

3.1 Performance measure 1: Element compliance and implementation

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

Type Required data Representation

Overall status Implementation Documented arrangements Target overall status

Figure 2: Suggested presentation of PM 1

3.2 Performance measure 2: Review and implementation of legislation and

This PM enables management to monitor implementation progress, tracking the number of

Table 3: Review and implementation of legislation and industry standards – PM

Type Required data Representation

Legislation and industry standards - review and

Identified Completed Overdue Scheduled

Figure 3: Suggested presentation of PM 2

3.3 Performance measure 3: Identified non-compliances with new