A Statement of Fitness is required by CP-117 [Ref. 6] and CP-122 “HSE Management Manual” and shall be included in the HSE Case.
A Statement of Fitness shall be developed for the Assets prior to teh pre start up audit for a project, before starting or commissioning a new Asset or a modification to an existing Asset.
Table 12 contains each element of the Statement of Fitness together with a guide to minimum requirements for demonstrate compliance with each element. Further guidance is provided in GU-648.
Table 12: Statement of Fitness
RequirEment
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DEMONSTRATION
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Process Safety Risks have been identified and documented and are managed to ALARP
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HSE Risk studies including HAZOP, HEMP, FERM and Bow-Ties have been completed
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ALARP demonstration has been made for the asset
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ALARP demonstration includes assessment of SIMOPS and development of a MOPO
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Risk register and Risk Management Plan in place
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An Emergency Response Plan addressing each of the identified Major Accident Hazards has been developed and is routinely tested
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Critical PCAP deliverables
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No outstanding unapproved variations to DEM1, DEM2 or actions from ALARP workshops
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Employees or Contractors executing HSE Critical Activities are competent and fit to work
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Operator competence assurance plans with HSE critical roles indentified in job descriptions
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Personnel in HSE Critical roles are fit to work
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TA approval framework is in place (DCAF or similar)
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Safety Critical Equipment meets its Technical Integrity Requirements
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SCEs have been indentified and documented and included in the HSE Case
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Performance Standards have been developed for all identified SCEs and approved by TAs
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PCAP in place & followed
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TIV Report (assurance and verification of the SCEs) finalized – all punch listed items closed out
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Design and Construction of new Assets and modifications to existing Assets meet design and engineering requirements
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All requirements of DEM 1 are met – a derogation register is maintained where DEPs cannot be satisfied
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Critical documents and drawings are prepared and approved.
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Well Handover Document completed
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Process Safety Basic Requirements are met
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All applicable PSBRs are met (DEM2)
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Procedures are in place to operate Safety Critical Elements within its Operational Limits.
The Asset Register, Safety Critical Elements (SCEs), SCE related Performance Standards (PSs) acceptance criteria and Maintenance / Inspection Routines are identified and loaded into the maintenance management system (SAP).
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Operations procedures are in place
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Integrity operating envelopes and Alarm Catalogues are completed
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Protection Device (Trip) settings in place, including wells
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Operations Procedures in place
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Performance Standards and maintenance/ inspection routines are current and uploaded to SAP
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Asset register is current and uploaded to SAP
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CMMS and SCE Management system is populated and available
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Corrosion management plans are in place
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Well integrity management is in place
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FSR is in place
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Modifications are complete and have been managed via the Management of Change process (PR-1001)
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Management of Change (MOC) Process is documented
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Staff in HSE Critical Positions are trained and a log maintained
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MOC procedures are in place and used
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A change register is maintained
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HSE audit and inspection programmes test compliance with the AI-PSM and HSE Case Standards
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Level 1, 2 and 3 audits are scheduled and completed as per the HSE Business Plan
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Audit findings are internally communicated to all levels in the organisation and a RAP developed
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All PDO Operations HSE Cases shall be reviewed on an annual basis (by year end) to ensure that all the following sections of the HSE Case remain true and valid to operations.
It is the responsibility of the Delivery Team Leader as the HSE Case Custodian to ensure these updates are completed, with support from the HSE Case administrator.
Bow-tie assessment
Have any new severity 5 or high level risks been identified?
Are all barriers still valid?
Have any new barriers been identified?
Are all barriers correctly categorised (Inherent Safety, SCE, Critical Activity)?
SCE listing
Is the hardware barrier correctly identified as an SCE?
Does the barrier have the correct SCE identifier attached?
Are all the performance standards complete and up to date?
Has all SCE been entered into the Asset Register?
Has the task information embedded within the system been added to the HSE Critical Task information?
HSE Critical Tasks
Has there been any Directorate/Departmental re-organisation?
Are all the reference indicators and positions still current?
Have all personnel signed off to say they are aware of their tasks (annual requirement) and that their assigned tasks are correct?
Remedial Actions
Are any of the remedial actions overdue?
Do any of these open action items compromise safe operations of the plant as signed in the Statement of Fitness?
Statement of Fitness
Annual review of the Statement of Fitness to ensure that it is correct and accurately reflects the status of operations.
The Statement of Fitness shall be signed off by the HSE Case Custodian after each review.
Other changes that may trigger a revision to the Operations HSE Case are listed below:
As part of a Material Change to the Facility, operation or surrounding environment that may have a potential impact on the risk profile
When it cannot be verified that the performance of safety critical elements (SCEs) meet the performance standards and/or when mitigation measures have been employed for extended periods to compensate for this shortfall
Prior to any material changes to the organisational arrangements or personnel levels
Following a major incident involving the Facility or operation, or from lateral learning from other major incidents applicable to the Facility or operation
Enhancements in knowledge or technology that change the basic assumptions on which the risk tolerability and ALARP demonstrations are based
Updated HEMP study findings/results
If there is a change to any of the signatory parties for the HSE Case, i.e. HSE Case Owner (Director), HSE Case Custodian (Delivery Team Leader) or HSE Case Administrator (Technical Safety Engineer)
All identified changes to the HSE Case, whether as a result of a periodic review or any of the other criteria listed above shall be assessed by the HSE Custodian, the Technical Safety Engineer and the HSE Case administrator (where this is not the TSE). Where relevant, the change should also be assessed by a discipline Technical Authority.
The roles and responsibilities for changes to the HSE Case and how these changes shall be recorded are further described in 31.
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