management system guideline hse process safety management...

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msg-hse-eni spa-eng-all S-C-r01

This document is the property of eni spa. All rights reserved.


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

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HSE



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

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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

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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.

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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.

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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;

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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.

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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.

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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.

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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.

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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;

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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.

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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

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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.

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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

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Accident Management and Management System Verification

Accident Investigation

Performance Indicators

Auditing

Management Review

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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.

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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.

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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.

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3.1.2 Compliance with standards


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.


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.

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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.

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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.

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3.1.3 Process Safety Competency


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.


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:

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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.

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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;

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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

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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

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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.



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Criteria and methods for managing competencies are defined in the MSG “Human

Resources” and in the eni documents relative to professional areas.

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3.1.4 Involvement of employees and contractors


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.


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).

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3.1.5 Consideration of Stakeholders' Needs


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.


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”

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3.2 Hazard identification and risk assessment

3.2.1 Process knowledge


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.


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”.

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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.



The methodologies and criteria and for knowledge management activities -re

defined in the MSG “Human Resources”.

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3.2.2 Hazard Identification, Risk Assessment and

Identification of Critical Elements for Safety and the Environment


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”.


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

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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).

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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.



The general criteria for hazard identification and risk assessment are defined in

the HSE MSG Attachment “HSE risk management”.

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3.3 Risk management

3.3.1 “Operating Manuals”


“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.


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.

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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.

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3.3.2 Work practices and permits


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.


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”.

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3.3.3. Inspections and Maintenance


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.


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.

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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.

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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”.

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3.3.4 Contractor management


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.


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

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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.

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3.3.5 Training


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.


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”.

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3.3.6 Management of Change


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.


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.

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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.

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3.3.7 Pre-Start Up Safety Review


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.


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.

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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”.

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3.3.8 Operation


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.


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.

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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.

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3.3.9 Emergency management


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.


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.

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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”.

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3.4 Accident management and management system

verification

3.4.1 Investigation


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.


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

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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)”.

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3.4.2 Indicators


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.


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“.

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3.4.3 Auditing


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:

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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.


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.

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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".

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3.4.4 Management Review


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.


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).

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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.

management system guideline hse process safety management...

Documents