Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

Contents

Authorisation for Issue

Amendment Record
Amendment Summary
Distribution List
Preface
List of Abbreviations

Paragraph Page
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1 Introduction 1

2 Monitoring 1
2.1 Group 1
2.2 Stream 1
2.3 Regional (United Kingdom
Continental Shelf (UKCS) Upstream) 2
2.4 Business Units 2
2.5 Delivery Unit 2

3 Audit of Compliance with Processes

and Procedures 3

4 Reviews 4

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 Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

Authorisation for Issue

Issue Authority
Name: Dave Ewen

Signature: ________________________________________________

Date: ________________________________________________

Position: Audit Relationship Manager

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Technical Authority
Name: Bill Cuthbert

Signature: ________________________________________________

Date: ________________________________________________

Position: Audit Relationship Manager, Business Audit, Aberdeen

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Amendment Record

For Audit Use

Amendment Incorporated By
Checked
Number
Name Signature Date Signature Date
Uncontrolled

AMOSAF.171

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 Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

Amendment Summary

Issue No Date Description

Issue 1 March 2001 First issue.
Issue 1/AM01 March 2002 Change of Technical Authority. Distribution List
updated.
Table 1 revised to update persons responsible for
ensuring audit is done.
Issue 1/AM02 April 2002 Issue Authority changed from Greg Owen to
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Dave Ewen. Distribution List updated.

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Distribution List

Holders of Controlled Hard Copy

Copy Copyholder Location

01 Data Control Centre (DCC) ODL, Aberdeen

Virtual Copyholders

Copy Copyholder
Uncontrolled

01 Document Issue Authority (Dave Ewen)

02 Document Technical Authority (Bill Cuthbert)
03 LTO Manager, Wytch Farm (Eamon Naughton)
04 EoS Document Controller (Dave Taylor)
05 EoS Operations Excellence HSE Consultant (David Egan)
06 OIM, Magnus
07 OIM, North West Hutton
08 OIM, Thistle
09 HSE/Compliance Manager, EoS
10 BSG SMS Co-ordinator (Peter Malcolm)
11 MNS SMS Co-ordinator (Peter Faulkner)
12 MNS SMS Co-ordinator (Peter Thompson)
13 MNS SMS Co-ordinator (Carl Thomessen)
14 MNS SMS Co-ordinator (Justin Haigh)
15 BU SMS Co-ordinator, CNS (Jim Blacklaws)
16 NBU SMS Co-ordinator (David Robertson)
17 NBU EPU SMS Co-ordinator (David Egan)
18 NBU SMS Co-ordinator (John Beaumont)
19 NSI SMS Co-ordinator (Ann Rosbrook)
20 SBU SMS Co-ordinator (Malcolm Watson)
21 SBU SMS Co-ordinator (Simon Robinson)
22 MNS SMS Co-ordinator (Bruce Morrison)

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 Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

Preface

Purpose
The purpose of this document is to describe the process used within BP for reviewing the
performance of the Safety Management System (SMS).
This document details the frequency and responsibility, at each management level, for carrying
out safety management monitoring and auditing.

Review and Update

Uncontrolled

This document will be subject to 12-monthly review and update, when document holders will
have the opportunity to express opinions and suggest improvements.
However, the document control system allows for continuous update of this document.
As such, any user may at any time identify an error or suggest an improvement using an
Amendment Proposal proforma which is available electronically on the UKCS SMS website,
from the Data Control Centre (DCC) Supervisor or from the Technical Authority.
All holders of this document are registered so that they can be sent updates and be kept
informed of changes or reviews.

Responsibility of Copyholders
It is the responsibility of the registered copyholder of controlled hard copy versions to
maintain the accuracy of the document by ensuring that all updates are promptly
incorporated and acknowledged.
Furthermore, the registered copyholder of controlled hard copy versions must at all times
maintain custody of this document unless prior approval is given by the relevant
Technical Authority.
The roles and responsibilities of copyholders and ‘virtual’ copyholders are detailed in Section 1
of the Document Control Procedure (UKCS-DCM-001).

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 Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

List of Abbreviations

ASA Advanced Safety Audit

BU Business Unit
BUL Business Unit Leader
CO2 Carbon Dioxide
DAFWC Days Away From Work Case
DU Delivery Unit
GHSER Getting HSE Right
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GVP Group Vice President

HSE Health, Safety and Environment
OIM Offshore Installation Manager
OSHA Occupational Safety and Health Administration
RWI Restricted Work Injuries
SCE Safety Critical Element
SMS Safety Management System
STOP Safety Training Observation Programme
UKCS United Kingdom Continental Shelf
UTG Upstream Technology Group
WoS West of Shetland

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 Policy for Monitoring/Audit/Review of SMS Performance UKCS-AL-001

1 Introduction
Health, Safety and Environment (HSE) performance within BP is managed through the
setting of Group expectations in Getting HSE Right (GHSER) and the setting of
performance targets at Group, stream, regional, Business Unit (BU) and Delivery
Unit (DU) levels. The Safety Management System (SMS) processes and procedures are
put in place to enable the meeting of these expectations and the delivery of the
performance targets.
Progress towards meeting the expectations and performance targets is
monitored through a set of performance indicators, usually collected together on a
performance scorecard.
Assurance that the processes and procedures are working as intended is provided
through regular audits of compliance of the processes and procedures.
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The effectiveness of the processes and procedures in meeting the expectations and
delivering the performance targets is achieved through a management review.
This is the distinctive difference between reviews and compliance audits.
The following paragraphs specify the minimum requirements for performance indicators,
compliance audits and reviews, and should be supplemented by further audits and
reviews as indicated by the individual BU or DU risk management processes.
In a very limited number of circumstances (eg BUR, Upstream Technology Group (UTG),
Terminals) some of the audits and reviews will not apply (eg well activity management).

2 Monitoring
HSE performance monitoring is carried at Group, stream, regional, BU and DU levels.

2.1 Group
Group data is a high level aggregation of the stream ‘Output data’ detailed below.

2.2 Stream
‘Output data’ on accidents, incidents, illnesses and spills is collected for upstream level
via the Operate 1 and Operate 2 spreadsheets. ‘Input data’ is collected on the following:
• Advanced Safety Audits (ASAs)
• Safety observations
• Safety training
• Closure of actions/findings
The input and output data is used to generate an upstream safety profile matrix featuring
all the upstream BUs. The distribution of this data is extensive and includes Group Vice
Presidents (GVPs), Business Unit Leaders (BULs) and BU HSE Team Leaders.
The responsibility for collation of this data is with the upstream HSE function.

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UKCS-AL-001 Policy for Monitoring/Audit/Review of SMS Performance

2.3 Regional (United Kingdom Continental Shelf

(UKCS) Upstream)
Safety performance is reported monthly to the Regional President, Regional Leadership
Team and Safety Governance Board. This includes accident and incident data, incident
severity potential, and near miss to accident ratio. The responsibility for collating the data
lies with the West of Shetland (WoS) HSE Team Leader (part of the devolved
Federal responsibilities).
Environmental performance is reported quarterly to the Environmental Governance
Board. Any significant environmental performance issues are taken to the Regional
Leadership Team by the Governance Board Chairman. The responsibility for collating this
data is with the Central Environmental Team.

2.4 Business Units

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Each BU produces a performance scorecard, updated at least monthly. The HSE
elements of the scorecard include, as a minimum (except where not applicable):
• Days Away From Work Cases (DAFWCs)
• Restricted Work Injuries (RWIs)
• Occupational Safety and Health Administration (OSHA) recordables
• Near miss to accident ratio
• Hydrocarbon leaks
• Dropped objects
• CO2 emissions
• Total hydrocarbon emissions
The data is reviewed monthly by the BU Management Team.
The responsibility for collation of the data lies with the BU HSE Team Leader.

2.5 Delivery Unit

Each DU produces a performance scorecard, updated at least monthly.
The HSE elements of the DU scorecard include, as a minimum (except where not
applicable), the metrics defined above for the BU scorecard, and data on ASAs and their
Safety Observation Programme (eg Safety Training Observation Programme (STOP)).
This data is reviewed monthly by the DU Management Team. The responsibility for
collating the data lies with the DU HSE Adviser.
’No leaks’ campaign data is collected monthly as per a standard performance scorecard.
This data is reviewed monthly by the DU Management Team. The responsibility for
collating the data lies with the DU ‘No Leaks’ Co-ordinator.

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Each DU will have a set of integrity-related measures. This will include

(where applicable):
• Safety Critical Element (SCE) performance standard anomalies (offshore BUs only)
• Overdue safety category maintenance
• Process upsets
• Normal maintenance backlog
• Overdue periodic inspections
• Corrosion control and monitoring
This data is to be reviewed monthly by each DU Management Team.
The responsibility for collating the data lies with the DU HSE Adviser.
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3 Audit of Compliance with Processes and Procedures

Audits of compliance are carried out to provide assurance that the processes and
procedures are working as intended. In some cases, the audits are a requirement of an
external accreditation, eg ISO 14001.
Table 1 defines the minimum mandatory audit requirements for ‘normal operations’ in
BUs which are part of the upstream UKCS region. Additional audits and/or increased
frequency should be applied when there is major organisational, procedural or structural
change within the BU.

Compliance Audit Minimum Frequency Responsibility for Ensuring

Audit is Done
Emergency Procedures Quarterly OIM, Terminal Manager or PUL
Operating Procedures Quarterly OIM, Terminal Manager or PUL
Maintenance Procedures Quarterly OIM, Terminal Manager or PUL
Competence Assurance Annually OIM, Terminal Manager or PUL
Permit to Work Weekly OIM, Terminal Manager or PUL
Appointment of Area and Quarterly OIM, Terminal Manager or PUL
Isolating Authorities
Management of Alarms Monthly OIM, Terminal Manager or PUL
and Trips, and Control
of Overrides
Management of Quarterly OIM, Terminal Manager or PUL
Long-term Isolations

Table 1 Minimum Mandatory Requirements for ‘Normal Operations’ in BUs

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Compliance Audit Minimum Frequency Responsibility for Ensuring

Audit is Done
Locked Valve Register Quarterly OIM, Terminal Manager or PUL
Management
Control of Lifting Equipment Quarterly OIM, Terminal Manager or PUL
and Lifting Operations
Control of Pressure Hoses Quarterly OIM, Terminal Manager or PUL
Storage and Control of Quarterly OIM, Terminal Manager or PUL
Explosives, Radioactive and
Hazardous Substances
Third-party and Quarterly OIM, Terminal Manager or PUL

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Hired Equipment
Site/Platform Quarterly OIM, Terminal Manager or PUL
Induction Process
Well Activity Management Quarterly OIM, Terminal Manager or PUL
Process for the Segregation, Quarterly OIM, Terminal Manager or PUL
Recycling and Management
of Waste
Management of Action Quarterly OIM, Terminal Manager or PUL
Tracking and Closeout

Table 1 Minimum Mandatory Requirements for ‘Normal Operations’ in BUs (cont’d)

4 Reviews
Reviews are carried out with the prime objective of determining the effectiveness of the
processes and procedures in meeting the expectations and delivering the performance
targets. This is distinctly different from compliance audits, which provide assurance that
the processes and procedures are working as intended.
Whilst the ultimate review is the comparison of actual performance against targets,
it is important that some key processes are reviewed individually. Table 2 defines the
minimum mandatory review requirements for BUs in the upstream UKCS region.
The term ‘internal’ means a review carried out by the BU or DU management,
but with outside help if necessary.
The term ‘external’ means a review (sometimes called an audit) carried out by personnel
from outside of the BU, but not necessarily outwith BP.

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Reviews Internal or Minimum Responsibility

External for Delivery
GHSER Annual Internal Annually HSE Team Leader
Self-assessment
Management and Internal Quarterly HSE Adviser
Closeout of
Actions
Safe System Internal Annually HSE Adviser
of Work
Emergency Internal Annually HSE Adviser
Exercise
Programme
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SMS Compliance Internal Annually HSE Adviser

Legislative Internal Annually HSE Adviser
Compliance
Management of Internal Annually Integrity Leader
Change
Technical Integrity Internal Annually Integrity Leader
Performance
Standards
Lessons Learned Internal Quarterly HSE Adviser
Health Plan Internal Annually HSE Adviser
Getting HSE Right External 3 yearly HSE Team Leader
External
ISO 14001 External As per HSE Team Leader
accreditation
Occupational External 3 yearly HSE Team Leader
Health
Occupational External 3 yearly HSE Team Leader
Hygiene
First Aid Needs External 2 yearly HSE Team Leader
Assessment

Table 2 Minimum Mandatory Review Requirements for

BUs in the Upstream UKCS Region

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