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PROCESS SAFETY MANAGEMENT CONCORDANCE TABLE

Comparison Of WCT HSE Management System (HSE MS) Documentation to the


Centre For Chemical Process Safety (CCPS) - Guidelines For Risk Based Process Safety
To promote process safety management excellence and continuous improvement throughout industry, CCPS created risk-based process safety (RBPS) as
the framework for the next generation of process safety management. The framework is built on four pillars which are further divided into 20 elements.
If an organization focuses its process safety efforts on these four pillars, then its process safety effectiveness should improve, the frequency and severity
of incidents should decrease, and the long term safety, environmental, and business performance should improve. This risk-based approach also helps
avoid gaps, inconsistencies, overwork, and underwork that can lead to system failure.

RBPS Pillar / Element Reference to Applicable Corporate


Comment
Key Principles Document for Compliance

Pillar 1: Commit to Process Safety The cornerstone of process safety excellence. A workforce that is convinced the organization
fully supports safety as a core value will tend to do the right things, in the right ways, at the right ties even when no one else is
looking.

1. Process Safety Culture - maintain a HSE MS, Element 2.2, Goals and Objectives Management is responsible for establishing and
dependable practice; development HSE MS, Element 2.3, Roles and Responsibilities supporting HSE Management System.
and implement and sound culture, HSE MS, Element 5.0, Review and Continual
HSE implementation plans outline stated objectives
monitor and guide the culture Improvement
and targets. Action plans include responsibilities and
HSE MS 3-Year Plans, Gap Analysis and
(OSHA PSM 1) timeframes.
Implementation Plans
HSE Manual, Section 1, Policy and Planning Every person in the organization has a personal
HSE Manual, Section 2, Roles and Responsibilities responsibility for HSE. Continued success of the
Annual Corporate Key Performance Indicators Companys HSE Management System means:
Corporate Asset Integrity Programs
Senior management is visibly committed.
Frontline management leads the process and is
actively involved.
Supervision is performance focused.
Workers are engaged and actively participating.

2. Compliance with Standards HSE MS, Introduction The HSE Management System provides a framework
ensure that a facility remains in HSE MS, Element 1.1, Management, Leadership to ensure that health, safety and environmental
conformance with applicable and Policy issues are systematically identified, controlled, and
standards, codes, regulations, and HSE MS, Element 2.2, Goals and Objectives monitored.
laws (including Company policy, HSE MS, Element 2.3, Roles and Responsibilities
The HSE MS is subject to periodic audit, ensuring
standards, and practices) HSE MS, Element 5.0, Review and Continual
business risk and regulatory needs / changes are
Improvement
(OSHA PSM 1) addressed.
HSE MS 3-Year Plans, Gap Analysis and
Implementation Plans
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

3. Process Safety Competency HSE MS, Element 2.1, Risk Management Company objectives include establishing a process
implement management systems to HSE MS, Element 3.4, Process Safety and Integrity to identify, evaluate and review training needs for
(1) help proactively identify learning Management each level and function within the organization and
needs, (2) support efforts to learn or HSE MS, Element 3.6, Employee and develop a training plan that addresses these needs.
obtain critical knowledge, (3) Organizational Capability Ensure that documentation of HSE and competency
maintain knowledge that helps HSE Manual, Section 9, Asset Integrity training is maintained.
promote risk-informed decision Corporate Asset Integrity Programs
The Company relies on a combination of skill-, rule-
making, and (4) share information.
, and knowledge-based decision making to achieve
(OSHA PSM 6) its HSE performance goals. The Companys overall
HSE Management System and the supporting
programs have been designed in consideration of
this model.

4. Workforce Involvement HSE MS, Element 2.3, Roles and Responsibilities Every person in the organization has a personal
involvement of workers who (1) are HSE MS, Element 2.1, Risk Management responsibility for HSE. Supervisors, employees and
aware of hazards at workplace, (2) HSE MS, Element 5.0, Review and Continual contractors are responsible for:
understand engineered controls and Improvement
Understanding current HSE regulations,
management systems provided to HSE MS 3-Year Plans, Gap Analysis and
address hazards, (3) accept and Implementation Plans guidelines and corporate policies related to their
strive to fulfill their roles and HSE Manual, Section 4, Risk Management area of responsibility.
responsibilities in support of providing HSE Manual Section 3, Site Safety Management Ensuring that all plans, practices, and
a safe work environment. Project HSE Assurance Plans procedures required to complete work in a safe
Environmental Protection Program and Plans and environmentally responsible manner, are
(OSHA PSM 5)
available and communicated.
Participating in HSE and competency training as
assigned

5. Stakeholder Outreach ensure that HSE MS, Element 4.1, Meetings and The Company commits to an open dialogue with
a facility retains a good relationship Communications employees, the communities in which it operates,
with stakeholders and establishes and HSE Manual, Section 1, HSE Management and other relevant stakeholders with respect to HSE
maintains connections with all HSE Manual, Section 2, Roles and Responsibilities issues associated with Company operations.
relevant industry, government, and HSE Manual, Section 3, Site Safety Management
public groups. HSE Manual, Section 5, Meetings and
Communications
(OSHA PSM 5)
Project HSE Assurance Plans
Company Environmental Protection Plans
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

Pillar 2: Understand Hazards and Risk The foundation of a risk-based approach. An organization can use this information to
allocate limited resources in the most effective manner.

6. Process Knowledge Management HSE MS, Element 4.5, Records Management Information systems in place to identify, collect,
focuses on information that can HSE MS, Element 3.4, Process Safety and Integrity protect, store, retrieve, route and dispose of HSE
easily be recorded in documents and Management documentation to assure operational integrity and
supports any effort to apply the risk- HSE Manual, Section 1, HSE Management regulatory compliance are in place.
based methods. Includes knowledge HSE Manual, Section 9, Asset Integrity
The Companys Management of Change (MOC)
of design intent, operating methods, HSE Manual, Section 15, Records Management
process is used to recognize, document, review and
equipment ratings, and process Environmental Protection Plan, Section 1
approve permanent or temporary physical and
hazards. Company Asset Integrity Manuals
operational changes, before they are made in order
(OSHA PSM 2) to ensure that the ability to manage pipeline and
pressure equipment integrity is not compromised by
such changes.

7. Hazard Identification and Risk HSE MS, Element 2.1, Risk Management Management is responsible for supporting risk
Analysis formal, documented HSE MS, Element 3.4, Process Safety and Integrity management programs and decisions.
review process of material, Management
Risks are identified, consistently evaluated and
equipment, location with respect to HSE Manual, Section 4, Hazard-Risk Management
mitigated using appropriate, reasonable and
people, sensitive environments and HSE Manual Section 3, Site Safety Management
practical risk management tools. Risks include
other vulnerable assets (new and Project HSE Assurance Plans
potential hazards, operational problems or non-
existing facilities Life-Cycle). Company Asset Integrity Manuals
compliance to: regulations, operating standards, or
Emergency Response Plans / CEPA E2 Risk
(OSHA PSM 3) safe work practices. Changes are recognized,
Assessments, as required
documented, formally reviewed and approved prior
Company Environmental Protection Plans
to their implementation and the continuation of work
as required to reduce business and operation risks.

Pillar 3: Manage Risk The ongoing execution of RBPS tasks. Organizations must (1) operate and maintain the processes that pose the
risk, (2) keep changes to those processes within risk tolerances, and (3) prepare for, respond to, and manage incidents that do occur.

8. Operating Procedures establish HSE MS, Element 2.1, Risk Management Work plans, practices and procedures are developed
requirements for all operating HSE MS, Element 3.1, Program Implementation and implemented, as required, for the work
procedures, assign responsibilities for HSE MS, Element 3.4, Process Safety and Integrity activities being conducted. They outline standard
development, use, and review, and Management operating and maintenance practices and procedures
address document control. HSE Manual, Section 4, Hazard-Risk Management and hazards.
HSE Manual, Section 3, Site Safety Management
(OSHA PSM 4)
HSE Manual, Section 9, Asset Integrity
HSE Manual, Section 12, Work Practices and
Procedures
Company Asset Integrity Manuals
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

9. Safe Work Practices establish HSE MS, Element 2.1, Risk Management Site-specific procedures are established and
subordinate procedures that govern HSE MS, Element 3.1, Program Implementation defined methods of performing site-specific
specific activities, including HSE Manual, Section 4, Hazard-Risk Management operations and address equipment and hazards not
responsibilities. HSE Manual, Section 3, Site Safety Management included in operating and maintenance procedures.
HSE Manual, Section 12, Work Practices and
(OSHA PSM 4)
Procedures

10. Asset Integrity and Reliability HSE MS, Element 3.4, Process Safety and Integrity The Company manages asset risk by providing an
defines standards or technical bases Management effective integrity management plan for designing,
used to develop the inspection, HSE Manual, Section 9, Asset Integrity constructing, maintaining, inspecting and operating
testing and preventative maintenance HSE Manual, Section 4, Risk Management Company pipeline systems and facilities to reduce
of equipment, management systems Company Asset Integrity Manuals loss, ensure worker safety and protect the
in place to ensure that (1) equipment environment through training and inspection.
deficiencies are report and managed,
These plans define the responsibilities and
(2) equipment is fabricated, installed
qualifications required for all personnel involved in
and maintained in accordance with
the management of programs and inspection of
specifications and certifications. Also,
production facilities.
defines roles and responsibilities and
the standards for training and
procedures to support this element.
(OSHA PSM 9)
HSE MS, Element 2.3, Roles and Responsibilities
11. Contractor Management systems The Company selects, hires, and assesses contractor
HSE Manual, Section 2, Roles and Responsibilities
to (1) consider contractor safety- personnel to ensure that the contracted workforce is
HSE Manual, Section 6, Qualifications, Orientations
related qualifications, (2) ensure composed of competent, capable workers equipped
and Training
contractors are made aware of facility with the skills required to meet the HSE
HSE Manual, Section 14, Contractor Management
and operational hazards and potential requirements for the services being contracted.
hazards introduced by contractor
Contractors performing work for the Company are
work activities, and (3) maintain high
expected to perform activities in a safe and
standards of safety performance
environmentally responsible manner, in accordance
during the conduct of contracted
with industry and specific craftsman trade rules,
services.
regulations and standard industry operating
(OSHA PSM 7) procedures.
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

12. Training and Performance HSE MS, Element 2.3, Roles & Responsibilities The Company selects, hires, trains and assesses its
Assurance includes education in HSE MS, Element 3.6, Employee & Organizational personnel to ensure that the workforce is composed
specific operations procedures, Capability of competent, capable workers equipped with the
maintenance, safe work, and HSE Manual, Site Safety Management skills required to meet the HSE requirements for
emergency planning and response, as HSE Manual, Section 6, Qualifications, their position.
well as overall process and its risks. Orientations & Training
Work activities commonly categorized HSE Manual, Section 9, Basic Safety
as skill-based, rule-based or HSE Manual, Section 14, Contractor Management
knowledge based. HSE Manual, Section 13, Work Practices and
Procedures
(OSHA PSM 6)
Environmental Protection Program, Section 6
Worker Competency / Training System (CMDS)
Company Asset Integrity Manuals

13. Management of Change establish HSE MS, Element 3.4, Process Safety and Integrity The Companys Management of Change (MOC)
formal authorization (documented) Management process is used to recognize, document, review and
and communication process HSE MS, Element 4.5, Records Management approve permanent or temporary physical and
(procedures, documentation, and HSE Manual, Section 4, Risk Management operational changes, before they are made in order
training) for all changes that are not HSE Manual, Section 9, Asset Integrity to ensure that the ability to manage equipment
replacements-in-kind. Specifically HSE Manual, Section 15, Records Management integrity is not compromised by such changes.
changes to facility design, activities, Company Asset Integrity Manuals
Risks are identified, consistently evaluated and
operations, organization or policies
mitigated using appropriate, reasonable and
that (1) introduce new hazards, or (2)
practical risk management tools. Risks include
increases risk of existing hazards.
potential hazards, operational problems or non-
(OSHA PSM 11) compliance to: regulations, operating standards, or
safe work practices.

14. Operational Readiness ensure HSE MS, Element 2.1, Risk Management The Companys Management of Change (MOC)
that processes that have been shut HSE MS, Element 3.4, Process Safety and Integrity process is used to recognize, document, review and
down are safe to restart. Includes Management approve permanent or temporary physical and
practices for pre-startup reviews of HSE MS Element 4.1, Meetings and operational changes, before they are made to
(1) new processes, (b) processes that Communications ensure the ability to manage equipment integrity is
have been shut down for modification, HSE Manual, Section 4, Hazard-Risk Management not compromised by such changes.
(3) process that have been HSE Manual, Section 3, Site Safety Management
The Company PSM process includes a requirement to
administratively shut down for other HSE Manual, Section 9, Asset Integrity
conduct Operational Readiness / Pre-Startup Safety
reasons. Project HSE Assurance Plans
Reviews (PSSR) as part of commissioning and start-
(OSHA PSM 8) up activities. The primary purpose is to ensure what
was designed and planned was carried out in the field
before facility startup. The emphasis is on the design
or significant design changes, calling attention to the
safety and operability of the facility.
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

15. Conduct of Operations establish HSE MS, Element 2.2, Goals and Objectives Every employee and contractor shares the
observable standards of behavior and HSE MS, Element 5.0, Review and Continual responsibility and is accountable for the safety and
accountability. Improvement environmental performance of the Company. The
HSE MS 3-Year Plans, Gap Analysis and HSE Management System is based on the principles
(OSHA PSM 10)
Implementation Plans of the Internal Responsibility & Accountability
HSE Manual, Section 1, Policy and Planning System (IRS).
HSE Manual, Section 2, Roles and Responsibilities
Management is responsible for establishing and
supporting clear HSE goals and objectives, roles and
responsibilities and supporting risk management
programs and decisions.
HSE implementation plans outline stated objectives
and targets. The action plans will include
responsibilities and timeframes.
Continually improve performance by having clear
roles, responsibilities and accountabilities for
Company personnel and contractors.

16. Emergency Management Plan for HS MS, Element 2.1, Risk Management The Company ensures proper planning and
emergencies. Define risks, roles and HS MS Element 3.3, Emergency Management preparation to ensure activation of response action
responsibilities, scope of response HSE Manual, Section 7, Emergency Preparedness plans and mobilization of response teams and
activities, train personnel and provide Project HSE Assurance Plans resources in a safe and effective manner, as well as
necessary equipment. Company Environmental Protection Plans coordinate activities with regulatory agencies;
thereby reducing the overall impact of the
(OSHA PSM 13)
emergency.

Pillar 4: Learn from Experience The opportunities for improvement. Metrics provide direct feedback on the workings of RBPS
systems, and leading indicators provide early warning signals of ineffective process safety results. When an elements performance is
unacceptable, organizations must use their mistakes and those of others as motivation for action.

17. Incident Investigation establish HSE MS, Element 2.1, Risk Management Incidents and near misses will be reported, analyzed
an incident reporting and investigation HSE MS, Element 4.2, Incident Management and investigated (as required). Investigation
process and competency. HSE Manual, Section 4, Risk Management findings and learnings will be documented and
HSE Manual, Section 8, Incident Reporting and communicated to minimize future occurrences.
(OSHA PSM 12)
Investigation Responsibilities for any corrective actions are
Company Environmental Protection Plans identified and timelines and personnel are assigned
to confirm that actions items are completed
RBPS Pillar / Element Reference to Applicable Corporate
Comment
Key Principles Document for Compliance

18. Measurement and Metrics a HSE MS, Element 2.2, Goals and Objectives A system is in place to monitor key leading and
means for near-real-time HSE MS, Element 5.0, Review and Continual lagging performance indicators, goals and
monitoring of performance and Improvement objectives of the corporation and each operating
efficiency of the process safety HSE MS 3-Year Plans, Gap Analysis and region and uses them to track and communicate
management system. Implementation Plans performance.
HSE Manual, Section 1, Policy and Planning
(OSHA PSM 14) Workplace behavior programs are in place to
HSE Manual, Section 2, Roles and Responsibilities
measure conformance with practices and
Annual Corporate Key Performance Indicators
procedures.
External benchmarking is conducted to ensure that
systems and programs are current and effective.

19. Auditing establish practice HSE MS, Element 4.3, Audits and Assessments The Company conducts audits and assessments to
including, (1) scope and objective of HSE MS, Element 4.4, Performance Monitoring and verify compliance with HSE standards and the
types of audits, (2) frequency and Reporting effectiveness of the HSE Management System.
depth of scrutiny, (3) organizational HSE MS, Element 5.0, Review and Continual
responsibilities, (4) resolution of Improvement
audit findings and HSE MS, Element 3.4, Process Safety and Integrity
recommendations, (5) Management
documentation requirements. HSE Manual, Section 5, Meetings & Communication
HSE Manual, Section 9, Asset Integrity
(OSHA PSM 14)
Environmental Protection Plans
Company Asset Integrity Manuals

20. Management Review and HSE MS, Element 2.2, Goals and Objectives Management is responsible for establishing and
Continuous Improvement HSE MS, Element 2.3, Roles and Responsibilities supporting clear HSE goals and objectives, roles and
ensure that required RBPS activities HSE MS, Element 5.0, Review and Continual responsibilities and supporting risk management
produce the desired results over the Improvement programs and decisions.
life of the facility, by establishing a HSE MS 3-Year Plans, Gap Analysis and
HSE implementation plans outline stated objectives
management review program, Implementation Plans
and targets. The action plans include responsibilities
conducting review activities, and Company Environmental Protection Program and
and timeframes.
monitoring organizational Environmental Protection Plans
performance. Annual Corporate Key Performance Indicators Senior management performs regular strategic
HSE Manual, Section 1, HSE Management Policy reviews of the HSE management system and the
(OSHA PSM 14)
and Planning and Section 6, Qualifications, Companys performance to confirm its suitability and
Orientations and Training effectiveness.

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