Process Safety Dossiers for Barrier Audit

The National Agency of Petroleum, Natural Gas and Biofuels (ANP) has been performing thematic audits in Oil and Gas’ offshore units of operating in Brazil. These thematic audits have the purpose of verifying how the operators are managing their Safety Critical Systems (SCS) to ensure their integrity, availability, and functionality during unit’s operational phase. This type of audit is performed over a self-diagnosis of the selected SCS, which shall assess its condition and describe the main information regarding the system’s suitability to perform its function. So far, ANP has covered the following SCS: Deluge; Drainage; Boarding Shutdown Valves (BSDV); Primary Containment; Fire & Gas (F&G) Detection; and Emergency Blowdown. Considering this diagnosis is not part of the unit specific documentation, nor part of Company’s Management System, and, at the same time, considering the value for operational safety of having the diagnosis of the SCS condition, SBM Offshore has identified the opportunity to issue an internal guideline for performing a SCS diagnosis, which was named as “Process Safety Dossiers” (PSD).

The PSD consists of a checklist, which addresses relevant questions to verify the SCS integrity, availability, and functionality, as well as the compliance with technical, regulatory, and internal standards and requirements. The dossiers bring questions that cover aspects of (i) design criteria, (ii) maintenance plan evaluation, (iii) quality of the tests evaluation, and (iv) competence of the personnel involved on the maintenance/test activities. For each question listed on PSD, the assessment team shall verify and evidence if: (i) YES - SCS is in place, available and in compliance with the requirement; (ii) NO - SCS is not in place, available or in compliance with the requirement; (iii) NI - No information is currently available to determine if the SCS is in compliance with the requirement; or (iv) NA - The requirement is not applicable for the SCS. Furthermore, for each requirement listed on the PSDa criticality is pre-defined as: (i) “A”, if the requirement deviation represents an immediate cessation or reduction of SCS ability to perform the required safety function; or (ii) “B”, if the requirement deviation does not represent an immediate cessation or reduction of SCS ability to perform the required safety function. So, mixing the compliance results with criticality pre-set, for the requirements evaluated as “NO” on the compliance and with criticality “A”, mitigation measures must be in place to reduce the associated risks to an acceptable level, and corrective measures must be proposed to bring the unit as compliant again. For the requirements evaluates as “NO” on the compliance and with criticality “B”, corrective measures shall be proposed for the same purpose but mitigations are not mandatory. If a requirement with criticality “A” is evaluated as “NI”, i.e., it cannot be verified, mitigation measures must be implemented until the assessment can be concluded.

SBM Offshore has developed and issued a total of 11 dossiers, covering the following SCS: Deluge; Drainage; BSDV; Primary Containment; F&G Detection; Emergency Blowdown; Emergency Response; Marine – Operations; Marine – Stability; Passive Fire Protection (PFP); and Safety Instrumented Functions (SIF).

The current step of the PSD project is to implement them during a safety barriers audit which is being performed at a pilot unit. The main purpose of this phase is to attest the quality and efficacy of the 11 PSD and to perform any required adjustment. This step is to be followed by the implementation of the PSD on all remaining SBM Offshore units operating in Brazil.

The objective of this paper is to present SBM Offshore strategy and a summary of lessons learned so far.